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BRUNO v. CETCO OILFIELD SERVICES CO et al Complaint

ATTENTION: It is possible that this information may no longer be current and therefore may be inaccurate. The index contains both open and closed cases and is not a complete list of cases in which an ACE Insurance Group company is involved. This information is provided to give interested persons an idea of the issues disputed in the indexed cases. For a full understanding of a case, one should read the rest of the court file, including the response. For the most up-to-date and complete information on a case, visit www.pacer.gov or contact the clerk of the relevant court.

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Case 6:11-cv-00837-RFD-PJH Document 1
Filed 06/07/11 Page 1 of 8 PageID #: 1
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION LINDA F. BRUNO VS CETCO OILFIELD SERVICES COMPANY, ENTERPRISE FM TRUST, AND ACE AMERICAN INSURANCE COMPANY CIVIL ACTION NO. JUDGE MAG. JUDGE
Complaint for Damages The petition of Linda F. Bruno, herein represented by undersigned counsel, represents upon information and belief that: Jurisdiction and Venue 1. Petitioner files this complaint under 28 U.S.C. § 1332(a)(1) as there is complete diversity of citizenship between all parties and the amount in countroversy exceeds $75,000, exclusive of interest and costs. 2. Venue is proper in this district under 28 U.S.C. § 1391(a)(2) because jurisdiction is based
Page 1 of 8
Case 6:11-cv-00837-RFD-PJH Document 1
Filed 06/07/11 Page 2 of 8 PageID #: 2
solely on complete diversity of citizenship and a substantial part of the events or omissions giving rise to the claim happened in the Lafayette Division of the Western District of Louisiana. The Parties 3. Petitioner is a citizen of the State of Louisiana and is a resident of lawful age and is domiciled in Lafayette, Lafayette Parish, Louisiana. 4. CETCO Oilfield Services Company (“CETCO”) is a citizen of the state of Delaware. It has its principal place of business at 2870 Forbs Avenue, Hoffman Estates, Illinois 60192. At all times material, it was and still does business in Louisiana and within this Court’s jurisdiction. It has appointed the C.T. Corporation System, 5615 Corporate Blvd., Suite 400B, Baton Rouge, Louisiana 70808 as its Louisiana registered agent for service of process. 5. Enterprise FM Trust (“Enterprise”) is a citizen of the State of Delaware. It has its principal place of business at 600 Corporate Park Drive, St. Louis, Missouri 63105. At all times material, it was and still does business in Louisiana and within this Court’s jurisdiction. It has appointed the C.T. Corporation System, 5615 Corporate Blvd., Suite 400B, Baton Rouge, Louisiana 70808 as its Louisiana registered agent for service of process. 6. Ace American Insurance Company (“Ace American”) is a citizen of the State of Pennsylvania. It has its principal place of business in Philadelphia, Pennsylvania 19105-1000. At all times material, it was and still is authorized to do and was and is still doing business in Louisiana Page 2 of 8
Case 6:11-cv-00837-RFD-PJH Document 1
Filed 06/07/11 Page 3 of 8 PageID #: 3
and within this Court’s jurisdiction. It has appointed the Louisiana Secretary of State as its agent for service of process, 8585 Archives Avenue, Baton Rouge, Louisiana 70809. The Facts 8. At all times material, petitioner was the registered owner and operator of a 2009 Honda Accord bearing Louisiana License Number RXA469. 9. At all times material, Enterprise was the registered owner of a 2008 Ford F-150 pickup truck bearing Louisiana License Number X423832. 10. At all times material, Stanford D. Broussard was the driver and sole occupant of this 2008 F-150 pickup truck. 11. At all times material, Stanford D. Broussard was a CETCO and/or Enterprise employee or servant. 12. At all times material, Stanford D. Broussard was driving this F-150 pickup truck with CETCO’s and/or Enterprise’s consent and permission, whether expressed or implied, relating to the duties, job, and work that CETCO and/or Enterprise had assigned to him, and he therefore was working in the course and scope of his employment with CETCO and/or Enterprise when the subject rear-end collision happened. CETCO and/or Enterprise is therefore responsible for Stanford D. Broussard’s fault and negligence. Page 3 of 8
Case 6:11-cv-00837-RFD-PJH Document 1
Filed 06/07/11 Page 4 of 8 PageID #: 4
13. On the early afternoon of Thursday, July 29, 2010, petitioner and Stanford D. Broussard were both traveling in an easterly direction on U.S. Highway 90 towards its intersection with Louisiana Highway 3184. Stanford D. Broussard was driving directly behind petitioner’s vehicle. 14. U.S. Highway 90 is a two-lane concrete or hard-surface roadway or highway with oncoming travel lanes for traffic traveling East and West. 15. At the intersection of the two roadways or highways, there is a single vehicle right exit lane for traffic moving from U.S. Highway 90 onto Louisiana Highway 3184, with a Yield Sign controlling traffic exiting from U.S. Highway 90 onto Louisiana Highway 3184. 16. Petitioner properly entered this single exit lane and stopped at the Yield Sign for traffic that was traveling in a southerly direction on Louisiana Highway 3184 in the outside lane. 17. On Thursday, July 29, 2011 at about 2:34 p.m. and while petitioner was stopped at the Yield Sign, Stanford D. Broussard crashed his F-150 pickup truck into the back of petitioner’s stopped Honda vehicle. 18. Both highways and the area where this rear-end collision happened are straight, straight, level, and flat. The roadways were dry and nothing obstructed or impaired Stanford D. Broussard’s vision. Page 4 of 8
Case 6:11-cv-00837-RFD-PJH Document 1
Filed 06/07/11 Page 5 of 8 PageID #: 5
Negligence 19. This rear-end collision happened so suddenly that petitioner, who was stopped when it happened, was unable to avoid it or prevent Stanford D. Broussard from crashing into the back of her stopped vehicle. 20. At the scene, Stanford D. Broussard told the investigating State Police Officer that he was looking toward his left at the southbound traffic on Louisiana Highway 3184 as he continued driving forward. 21. Louisiana Revised Statutes, Title 32, Section 58 provides that “Any person operating a motor vehicle on the public roads of this state shall drive in a careful and prudent manner, so as not to endanger the life, limb, or property of any person. Failure to drive in such a manner shall constitute careless operation.” 22. Petitioner was operating her vehicle in a legal, careful, and prudent manner. This rear-end collision was due solely, exclusively, and proximately to the negligence, carelessness, and fault of the defendants’ driver-employee, Stanford D. Broussard, in the following nonexclusive particulars: A. B. C. D. Operating his vehicle in disregard for petitioner’s safety; Operating his vehicle in a careless manner; Failing to keep a proper lookout for traffic in front of him; Failing to timely see that petitioner’s vehicle was stopped at the Yield Sign; Page 5 of 8
Case 6:11-cv-00837-RFD-PJH Document 1
Filed 06/07/11 Page 6 of 8 PageID #: 6
E.
Failing to see what he should have seen and do what he should have done under the circumstances; Violating the provisions of La. R.S. 32:58; Failing to obey the laws and regulations pertinent to traffic for Lafayette Parish and the State of Louisiana. 23.
F. G.
Petitioner’s injuries and damages were caused by the defendants’ legal fault, negligence, careless, and omission of duty—as they are vicariously liable for the fault and negligence of their employee, agent, or servant, Stanford D. Broussard—and without any legal fault, negligence, careless, or omission of duty by petitioner or in any way contributing to this rear-end collision. Damages 24. Petitioner has and will continue to indefinitely suffer injuries to her cervical spine, shoulders, and related bodily injuries, mental anguish, distress, and the loss or diminishment of enjoyment of life. Petitioner does not know the full extent of her injuries at this time, but they have and will continue to require medical care and treatment. 25. Because of her injuries, petitioner is entitled to recover under the Louisiana Code of Civil Procedure Articles 893 and 861 all reasonable amounts for all general and special damages, past, present and future, and which include by example the following: A. B. C. Physical pain, suffering, and disfigurement; Mental anguish and distress; Loss or diminishment of the enjoyment of life; Page 6 of 8
Case 6:11-cv-00837-RFD-PJH Document 1
Filed 06/07/11 Page 7 of 8 PageID #: 7
D. E.
Medical and hospital costs; Wage losses and/or the loss and/or diminishment of earning capacity. Insurance 26.
At all times material, Ace American Insurance Company insured the defendants under a policy of liability insurance that was in full force and effect when this rear-end collision happened and, as such, it is jointly and solidarily liable with the other defendants to pay all of petitioner’s damages. 27. Ace American Insurance Company’s policy contains no provisions or exclusions that are applicable to this rear-end motor-vehicle collision and, as such, it is liable to pay petitioner’s damages up to the full amount of its policy limits. Prayer Petitioner, Linda F. Bruno, prays that after due proceedings are had, the Court render judgment in her favor and against the defendants CETCO Oilfield Services Company, Enterprise FM Trust, and Ace American Insurance Company, for general and special damages in such amounts as are fair and reasonable, plus legal interest thereon from date of judicial demand until paid, and for all costs of these proceedings. Finally, petitioner prays for such further orders and relief to which she is entitled whether at law or in equity.
Page 7 of 8
Case 6:11-cv-00837-RFD-PJH Document 1
Filed 06/07/11 Page 8 of 8 PageID #: 8
Respectfully submitted, RICHARD R. KENNEDY (APLC) 309 Polk Street P.O. Box 3243 Lafayette, LA 70502-3243 Phone: (337) 232-1934 Fax: (337) 232-9720 E-Mail: ken309@richardkennedy.com E-Mail: rrk3@richardkennedy.com BY: /s/ Richard R. Kennedy RICHARD R. KENNEDY (# 7788), T.A. Attorneys for Linda F. Bruno
N:\Client\BrunoL\Pleadings\Petition\Complaint.wpd
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Case 6:11-cv-00837-RFD-PJH Document 1-1
""'JS 44 (Rev. 11104)
Filed 06/07/11 Page 1 of 2 PageID #: 9
CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of Initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
I. (a)
PLAINTIFFS
DEFENDANTS
LINDA F. BRUNO
(b)
County of Residence of First Listed Plaintiff
CETCO Oilfield Services Co" Enterprise FM Trust, and Ace American Ins, Co.
~~~~---------
Louisiana
County of Residence of First Listed Defendant
Delaware & Pennsylvania
(EXCEPT IN U.S. PLAINTIFF CASES)
(IN U.S. PLAINTIFF CASES ONLY) NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE LAND INVOL VED.
(c)
Attorney's (Finn Name, Address, and Telephone Number)
Attorneys (If Known)
Richard R. Kennedy, P.O. Box 3243, Lafayette, LA 70502 (337) 232-1934
II.
01 BASIS OF JURISDICTION U.S. Government Plaintiff (Place an "X" in One Box Only)
Unknown
III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an "X" in One Box for Plaintiff (For Diversity Cases Only) and One Box for Defendant) PTF DEF PTF DEF Citizen of This State ~ I I Incorporated or Principal Place 0 4 0 4 of Business In This State
o
3 Federal Question (U.S. Government Not a Party)
o
o
2
U.S. Government Defendant
II 4 Diversity
(Indicate Citizenship of Parties in Item Ill)
Citizen of Another State
o o
2
..
2
Incorporated and Principal Place of Business In Another State Foreign Nation
o o
5
ill 5
0 6
Citizen or Subject of a Forei Couo IV. NATURE F ONTRACT
3
0
3
6
o
SUIT
0 0 0 0 0 0
(Place an "X" in One Box Only) TORTS PERSONAL INJURY 310 Airplane 3 15 Airplane Product Liability 320 Assault, Libel & Slander 330 Federal Employers' Liability 340 Marine 345 Marine Product Liability 350 Motor Vehicle 355 Motor Vehicle Product Liability 360 Other Personal Injury CIVIL RIGHTS 441 Voting 442 Employment 443 Housing! Accommodations 444 Welfare 445 Arner. wlDisabilitiesEmployment 446 Arner. wlDisabilitiesOther 440 Other Civil Rights PERSONAL INJURY 0 362 Personal Injury ­ Med. Malpractice 0 365 Personal Injury Product Liability 0 368 Asbestos Personal Injury Product Liability PERSONAL PROPERTY 0 370 Other Fraud 0 371 Truth in Lending 0 380 Other Personal Property Damage 0 385 Property Damage Product Liability PRISONER PETITIONS 510 Motions to Vacate Sentence H.b••• Corpus: 0 530 General 0 535 Death Penalty 0 540 Mandamus & Other 0 550 Civil Rights 0 555 Prison Condition 0
FORFEITUREIPENALTY 0 0 0 0 0 0 0 0 0 0 0 0 0 0 610 Agriculture 620 Other Food & Drug 625 Drug Related Seizure of Property 21 USC 88 I 630 Liquor Laws 640 R.R. & Truck 650 Airline Regs. 660 Occupational Safety/Health 690 Other ,ADOR 710 Fair Labor Standards Act 720 LaborlMgmt. Relations 730 LaborlMgmt. Reporting & Disclosure Act 740 Railway Labor Act 790 Other Labor Litigation 791 Empl. Ret. Inc. Security Act
BANKRUPTCY
OTHER STATUTES
o o o o o o o o o o o o o o o o o o
110 Insurance 120 Marine 130 Miller Act 140 Negotiable Instrument 150 Recovery of Overpayment & Enforcement of Judgment 151 Medicare Act 152 Recovery of Defaulted Student Loans (Exc!. Veterans) 153 Recovery of Overpayment of Veteran's Benefits 160 Stockholders' Suits 190 Other Contract 195 Contract Product Liability 196 Franchise REAL PROPERTY 210 Land Condemnation 220 Foreclosure 230 Rent Lease & Ejectment 240 Torts to Land 245 Tort Product Liability 290 All Other Real Property
o o
422 Appeal 28 USC 158 423 Withdrawal 28 USC 157 PROPER' YRI HrS
0 0 0 0
0 0 0 0
o 820 Copyrights o 830 Patent o 840 Trademark o o o o o o
III
0 0
0 0 0 0 0 0 0
SOCIA ,SE JRl 'Y 861 HIA (I 395fl) 862 Black Lung (923) 0863 DIWCIDIWW (405(g)) 864 ssm Title XVI 865 RSI (405(g)) FEDERAL TAX SUITS 870 Taxes (U.S. Plaintiff or Defendant) 871 IRS-Third Party 26 USC 7609
0 0
0 0 0 0 0 0 0 0
0
400 State Reapportionment 410 Antitrust 430 Banks and Banking 450 Commerce 460 Deportation 470 Racketeer Influenced and Corrupt Organizations 480 Consumer Credit 490 Cable/Sat TV 810 Selective Service 850 Securities!Commodities! Exchange 875 Customer Challenge 12 USC 3410 890 Other Statutory Actions 891 Agricultural Acts 892 Economic Stabilization Act 893 Environmental Matters 894 Energy Allocation Act 895 Freedom ofinfonnation Act 900Appeal ofFee Detennination Under Equal Access to Justice 950 Constitutionality of State Statutes
V. ORIGIN
(Place an "X" in One Box Only)
~I
Original Proceedin
o
2
Removed from State Court
0 3
Remanded from A ellate Court
o
4
Reinstated or Reo ened
0 5
Transferred from another district s ecif
0 6
Multidistrict Liti ation
o
7
Appeal to District Judge from Magistrate Jud ment
q~ \1.~C'. C~v6~t~~Jj under which you are filing (Do not cite jurisdictional statutes unless diversity):
VI. CAUSE OF ACTION Brief descrigtion of cause:
Personal mjury claim for damages suffered in a motor-vehicle collision.
CHECK IF THIS IS A CLASS ACTION DEMAND $ UNDER F.R.C.P. 23 500,000.00 (See insttuctions): CHECK YES only if demanded in complaint: JURY DEMAND:
VII. REQUESTED IN COMPLAINT: VIII. RELATED CASE(S) IFANY DATE
0 Yes
ill No
DOCKET NUMBER
06/07/2011
FOR OFFICE USE ONLY RECEIPT #
-------- AMOUNT
----------~
JUDGE
---------
MAG. JUDGE
--------------­
Case 6:11-cv-00837-RFD-PJH Document 1-1
JS 44 Reverse (Rev. 11104)
Filed 06/07/11 Page 2 of 2 PageID #: 10
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as required by law. except as provided by local rules of court This form, approved by the Judicial Conference ofthe United States in September 1974, is required for the use ofthe Clerk ofCourt for the purpose of initiating the civil docket sheet. Consequently, a civi I cover sheet is submitted to the Clerk of Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I. (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. Ifthe plaintiff or defendant is a government agency, use only the full name or standard abbreviations. Ifthe plaintiff or defendant is an official within a government agency, identify first the agency and then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name ofthe county where the first listed plai ntiff resides at the time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.) (c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting in this section "(see attachment)". II. Jurisdiction. The basis ofjurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an "X" in one of the boxes. If there is more than one basis ofjurisdiction, precedence is given in the order shown below. United States plaintiff. (I) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here. United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box. Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and box I or 2 should be marked. Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship of the different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)
III.
Residence (citizenship) of Principal Parties. This section ofthe JS 44 is to be completed ifdiversity ofcitizenship was indicated above. Mark this sectior. for each principal party.
IV. Nature ofSuit. Place an "X" in the appropriate box. Ifthe nature of suit cannot be determined, be sure the cause ofaction, in Section VI below, is sufficient to enable the deputy clerk or the statistical clerks in the Administrative Office to determine the nature of suit. If the cause fits more than one nature of suit, select the most definitive. V. Origin. Place an "X" in one of the seven boxes.
Original Proceedings. (I) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.c., Section 1441. When the petition
for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the tiling date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict
litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.c. Section 1407. When this box
is checked, do not check (5) above.
Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judge's decision.
VI. Cause of Action. Report the civil statute directly related to the cause ofaction and give a brief description ofthe cause. Do not cite jurisdictional statutes
unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: UnauthoTlzed reception of cable service
VII.
Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
)emand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.
fury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
vIII. Related Cases. This section of the JS 44 is used to reference related pending cases if any. Ifthere are related pending cases, insert the docket numbers
md the corresponding judge names for such cases.
late and Attorney Signature. Date and sign the civil cover sheet.
Case 6:11-cv-00837-RFD-PJH Document 1-2
AO 440 (Rev. 12/09) Summons in a Civil Action
Filed 06/07/11 Page 1 of 2 PageID #: 11
UNITED STATES DISTRICT COURT
for the
Western District of __________ __________District of Louisiana
LINDA F. BRUNO
Plaintiff
v.
CETCO Oilfield Services Company, et al
Defendant
) ) ) ) ) ) )
Civil Action No.
SUMMONS IN A CIVIL ACTION To: (Defendant’s name and address) CETCO Oil Field Services Company
C T Corporation Stystem 5615 Corporate Blvd., Suite 400B Baton Rouge, LA 70808
A lawsuit has been filed against you. Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are:
Richard R. Kennedy, Esq. Richard R. Kennedy (APLC) 309 Polk Street P.O. Box 3243 Lafayette, LA 70502-3243
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 6:11-cv-00837-RFD-PJH Document 1-2
AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
Filed 06/07/11 Page 2 of 2 PageID #: 12
Civil Action No. PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l)) This summons for (name of individual and title, if any) was received by me on (date) .
’ I personally served the summons on the individual at (place) on (date) ’ I left the summons at the individual’s residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual’s last known address; or , who is on (date) ’ I returned the summons unexecuted because ’ Other (specify): . ; or ; or ; or
’ I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization)
My fees are $
for travel and $
for services, for a total of $
0.00
.
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Print
Save As...
Reset
Case 6:11-cv-00837-RFD-PJH Document 1-3
AO 440 (Rev. 12/09) Summons in a Civil Action
Filed 06/07/11 Page 1 of 2 PageID #: 13
UNITED STATES DISTRICT COURT
for the
Western District of __________ __________District of Louisiana
LINDA F. BRUNO
Plaintiff
v.
CETCO Oilfield Services Company, et al
Defendant
) ) ) ) ) ) )
Civil Action No.
SUMMONS IN A CIVIL ACTION To: (Defendant’s name and address) Enterprise FM Trust
C T Corporation Stystem 5615 Corporate Blvd., Suite 400B Baton Rouge, LA 70808
A lawsuit has been filed against you. Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are:
Richard R. Kennedy, Esq. Richard R. Kennedy (APLC) 309 Polk Street P.O. Box 3243 Lafayette, LA 70502-3243
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 6:11-cv-00837-RFD-PJH Document 1-3
AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
Filed 06/07/11 Page 2 of 2 PageID #: 14
Civil Action No. PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l)) This summons for (name of individual and title, if any) was received by me on (date) .
’ I personally served the summons on the individual at (place) on (date) ’ I left the summons at the individual’s residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual’s last known address; or , who is on (date) ’ I returned the summons unexecuted because ’ Other (specify): . ; or ; or ; or
’ I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization)
My fees are $
for travel and $
for services, for a total of $
0.00
.
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Print
Save As...
Reset
Case 6:11-cv-00837-RFD-PJH Document 1-4
AO 440 (Rev. 12/09) Summons in a Civil Action
Filed 06/07/11 Page 1 of 2 PageID #: 15
UNITED STATES DISTRICT COURT
for the
Western District of __________ __________District of Louisiana
LINDA F. BRUNO
Plaintiff
v.
CETCO Oilfield Services Company, et al
Defendant
) ) ) ) ) ) )
Civil Action No.
SUMMONS IN A CIVIL ACTION To: (Defendant’s name and address) Ace Amercian Insurance Company
Louisiana Secretary of State 8585 Archives Avenue Baton Rouge, LA 70809
A lawsuit has been filed against you. Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney, whose name and address are:
Richard R. Kennedy, Esq. Richard R. Kennedy (APLC) 309 Polk Street P.O. Box 3243 Lafayette, LA 70502-3243
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 6:11-cv-00837-RFD-PJH Document 1-4
AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
Filed 06/07/11 Page 2 of 2 PageID #: 16
Civil Action No. PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l)) This summons for (name of individual and title, if any) was received by me on (date) .
’ I personally served the summons on the individual at (place) on (date) ’ I left the summons at the individual’s residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual’s last known address; or , who is on (date) ’ I returned the summons unexecuted because ’ Other (specify): . ; or ; or ; or
’ I served the summons on (name of individual) designated by law to accept service of process on behalf of (name of organization)
My fees are $
for travel and $
for services, for a total of $
0.00
.
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Print
Save As...
Reset

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