NOTICE OF ELECTRONIC FILING - Lawyers USA OnlineAlaFile E-Notice To: CLINT MOUNTAIN [email protected] 63-CV-2012-900178.00 NOTICE OF ELECTRONIC FILING IN THE CIRCUIT COURT OF TUSCALOOSA

AlaFile E-Notice

To: CLINT MOUNTAIN

[email protected]

63-CV-2012-900178.00

NOTICE OF ELECTRONIC FILING

IN THE CIRCUIT COURT OF TUSCALOOSA COUNTY, ALABAMA

The following complaint was FILED on 3/1/2012 2:32:23 PM

JUAKEISHIA VONSHAI PRUITT V. BYRON E. HOUSE ET AL

63-CV-2012-900178.00

Notice Date: 3/1/2012 2:32:23 PM

MAGARIA HAMNER BOBO

CIRCUIT COURT CLERK

TUSCALOOSA COUNTY, ALABAMA

714 GREENSBORO AVENUE

TUSCALOOSA, AL 35401

205-349-3870

[email protected]

State of Alabama

Unified Judicial System

Form ARCiv-93 Rev.5/99

COVER SHEETCIRCUIT COURT - CIVIL CASE

(Not For Domestic Relations Cases)

Case Number:

Date of Filing:

63-CV-2012-900178.00

03/01/2012

Judge Code:

GENERAL INFORMATION

IN THE CIRCUIT OF TUSCALOOSA COUNTY, ALABAMA

First Plaintiff:

JUAKEISHIA VONSHAI PRUITT v. BYRON E. HOUSE ET AL

Business

Government

Individual

Other

BusinessFirst Defendant:

Government

Individual

Other

NATURE OF SUIT:

TORTS: PERSONAL INJURY

WDEA - Wrongful Death

TONG - Negligence: General

TOMV - Negligence: Motor Vehicle

TOMM - Malpractice-Medical

TOPL - Product Liability/AEMLD

TOWA - Wantonnes

TOLM - Malpractice-Legal

TOOM - Malpractice-Other

TBFM - Fraud/Bad Faith/Misrepresentation

TOXX - Other:

TORTS: PERSONAL INJURY

TOPE - Personal Property

TORE - Real Property

OTHER CIVIL FILINGS

ABAN - Abandoned Automobile

ACCT - Account & Nonmortgage

APAA - Administrative Agency Appeal

ADPA - Administrative Procedure Act

ANPS - Adults in Need of Protective Services

OTHER CIVIL FILINGS (cont'd)

MSXX -

CVRT - Civil Rights

COND - Condemnation/Eminent Domain/Right-of-Way

CTMP-Contempt of Court

CONT-Contract/Ejectment/Writ of Seizure

Birth/Death Certificate Modification/Bond ForfeitureAppeal/Enforcement of Agency Subpoena/Petition toPreserve

TOCN - Conversion

EQND- Equity Non-Damages Actions/DeclaratoryJudgment/Injunction Election Contest/Quiet Title/Sale ForDivision

CVUD-Eviction Appeal/Unlawfyul Detainer

FORJ-Foreign Judgment

FORF-Fruits of Crime Forfeiture

MSHC-Habeas Corpus/Extraordinary Writ/Mandamus/Prohibition

PFAB-Protection From Abuse

FELA-Railroad/Seaman (FELA)

RPRO-Real Property

WTEG-Will/Trust/Estate/Guardianship/Conservatorship

COMP-Workers' Compensation

CVXX-Miscellaneous Circuit Civil Case

ORIGIN: F

R

A

T

INITIAL FILING

REMANDED

APPEAL FROMDISTRICT COURT

TRANSFERRED FROMOTHER CIRCUIT COURT

O OTHER

HAS JURY TRIAL BEEN DEMANDED? Yes No

RELIEF REQUESTED: MONETARY AWARD REQUESTED NO MONETARY AWARD REQUESTED

MEDIATION REQUESTED: Yes No Undecided

ATTORNEY CODE: MOU012 3/1/2012 1:59:29 PM /s/ CLINT MOUNTAIN

ELECTRONICALLY FILED3/1/2012 2:32 PM

CV-2012-900178.00CIRCUIT COURT OF

TUSCALOOSA COUNTY, ALABAMAMAGARIA HAMNER BOBO, CLERK

IN THE CIRCUIT COURT OF TUSCALOOSA, ALABAMA

JUAKEISHIA VONSHAI PRUITT, )Plaintiff. )

)vs. )

)BYRON E. HOUSE, an individual, ) Case No.: BOBBY COCKRELL, JR., )an individual, )COCKRELL AND COCKRELL, )an unincorporated business entity, )and fictitious )defendants A through H, )

Defendants. )

COMPLAINT

STATEMENT OF THE PARTIES

1. The Plaintiff, Shai Pruitt, is a resident citizen of Tuscaloosa County, Alabama,and is over the age of nineteen (19) years.

2. The Defendant, Byron E. House, is a resident citizen of Tuscaloosa County,Alabama, and is over the age of nineteen (19) years.

3. The Defendant, Bobby Cockrell, Jr., is a resident citizen of Tuscaloosa County,Alabama, and is over the age of nineteen (19) years.

4. The Defendant, Cockrell and Cockrell, is a business entity providing legalservices in Tuscaloosa, County.

5. Fictitious defendants A through D, whether singular or plural, are the persons,firms, proprietorships, partnerships, corporations, and/or entities other than the abovenamed Defendants, who or which caused or contributed to the Plaintiff’s damages.

6. Fictitious defendants E through H, whether singular or plural, are the persons,firms, proprietorships, partnerships, corporations, and/or entities other than the abovenamed Defendants who exercised any right of control over any of the defendants, namedor unnamed, and/or negligently/wantonly supervised, hired, trained or retained anyperson(s), who or which caused or contributed to the Plaintiff’s damages.

7. The Plaintiff asserts that the identities of these fictitious defendants presentlyunknown to her, and that their true names will be added by amendment when soascertained.




STATEMENT OF THE FACTS 8. Byron E. House is an attorney, licensed to practice law in the State of Alabama,and provided legal services to the Plaintiff on many occasions.

9. Byron E. House was a member of the Law Firm of Cockrell and Cockrell and atall times acted as an agent conducting business on their behalf.

10. Bobby Cockrell, Jr., is the managing partner of Cockrell and Cockrell, a law firmproviding legal services in the State of Alabama.

11. Defendant House agreed to represent the Plaintiff Pruitt in an action againstStillman College for discrimination.

12. Pruitt employed Byron E. House and Cockrell and Cockrell some time in October2006 to represent her against Stillman College.

13. Around November of 2006, Defendant House notified Pruitt that her case againstStillman College was settled and she needed to execute a release.

14. On November 16, 2006, Pruitt executed a release drafted and presented to her byDefendant House. (Exhibit A)

15. The release detailed her alleged settlement and promised her an initial lump sumof twenty-five thousand dollars ($25,000.00), which was paid to Pruitt on that day, andfifty-nine (59) monthly payments of three thousand, five hundred forty-one dollars andsixty-six cents ($3,541.66).

16. Pruitt was to receive a total disbursement of two hundred thirty-three thousand,nine hundred fifty-seven dollars and ninety-four cents ($233,957.94) plus interest asthose funds were to be placed in an annuity.

17. Those payments were to be made to Pruitt by House and Cockrell and Cockrell astrustee of the settlement proceeds.

18. Pruitt co-signed documents with Byron E. House and Cockrell and Cockrellpurportedly for the administration of her settlement proceeds. (Exhibit B)

19. Payments in the amount of three thousand, five hundred forty-one dollars andsixty-six cents ($3,541.66) were made until April of 2009 at which time House informedPruitt that the investment company paying the structured settlement was “goingbankrupt” and her monthly payments were being cut to one thousand, nine hundredeighty dollars ($1,980.00).

20. Payments in the new amount were made until January 5, 2012. (Exhibit C)

21. In January of 2012, Pruitt discovered that there may or may not be a structuredsettlement and does not know whether the case was in fact settled for that amount.

22. During that time, House agreed to represent Pruitt in a separatediscrimination/wrongful termination lawsuit against her former employer, Averitt/i3,stemming from actions that occurred on or around August of 2006.

23. An EEOC Charge of Discrimination had previously been filed for Pruitt onFebruary 16, 2007, by an attorney, Benjamin L. Woolf, who began representation ofPruitt for her potential claims against Averitt/i3. (Exhibit D)

24. Pruitt discontinued her employment of Woolf and retained House and Cockrelland Cockrell in October of 2007 to represent her against Averitt/i3, primarily based ontheir success with her case against Stillman College.

25. House represented to Pruitt that he filed a lawsuit against Averitt/i3 shortly aftershe retained his services and that they were awaiting trial.

26. From that time until December of 2011, she frequently communicated with Houseabout her pending suit and he reassured they were waiting on a trial date.

27. House informed Pruitt that they were going to trial on several different occasions,but before the supposed trial dates he would call her and tell her that the case had beencontinued.

28. House continued to tell Pruitt that he was trying to settle her case throughDecember of 2011.

29. In December of 2011, House informed Pruitt that he had agreed with the allegedDefendants to settle her case for one million, six hundred fifty thousand dollars($1,650,000.00) and he was trying to negotiate how quickly that amount would be paid.

30. In December of 2011, Pruitt became suspicious of House and requested her casenumber so she could inquire with the court about the disposition of her case.

31. House provided her with a false case number, which was actually heradministrative claim number from her EEOC filing, to deceive Pruitt.

32. In January of 2012 after standing her up for an appointment to “go over the finalpaperwork”, Pruitt became suspicious and learned that she did not have a case pendingagainst Averitt/i3, nor had suit ever been filed on her behalf.

33. In January of 2008, Pruitt was injured in an automobile accident when a drunkdriver struck a vehicle in which she was a passenger.

34. Pruitt secured the services of Byron E. House to handle her claims against theDefendant driver.35. House informed Pruitt in February of 2010 that the case was settled and she wasto receive five thousand dollars ($5,000.00) and her outstanding medical bills.

36. Recently, Pruitt discovered that House did not pay her medical bills as promisedto both her and the medical care providers.

37. It is Pruitt’s belief that this case was never filed or handled in accordance withordinary and reasonable skills causing her economic loss.

38. In 2009, House agreed to represent Pruitt in a contract action against A-Plusphotography.

39. Pruitt alleged that A-Plus did not give her many of her wedding pictures ascontracted for in 2007.

40. Specifically, A-Plus photography did not provide pictures of Pruitt’s weddingparty, bridal pictures or wedding party.

41. In 2011, House informed Pruitt that she had obtained a judgment against A-PlusPhotography in the amount of five thousand dollars ($5,000.00).

42. House advised Pruitt to settle with A-Plus Photography for one thousand fivehundred dollars to satisfy the outstanding judgment.

43. It is now believed that no case was filed against A-Plus Photography nor wasthere ever a judgment entered against A-Plus Photography.

44. All of the above actions are now time-barred by the applicable statute oflimitations.

45. As a result of the Defendants’ negligent/wanton conduct, the Plaintiff sufferedeconomic damages, mental anguish and emotional distress.

COUNT ONE – ALABAMA LEGAL SERVICES LIABILITY ACT

46. This action is brought pursuant to the Alabama Legal Services Liability Act,Code of Alabama 1975 § 6-5-570, et seq.

47. The Plaintiff realleges all previous paragraphs of the complaint. 48. Plaintiff contracted with Defendants to perform for Plaintiff certain professional,legal services on her behalf. Defendants are attorneys licensed to practice in Alabama.

49. The Defendants failed to perform their duties in the same manner as an attorneyin Alabama who possessed and exercised ordinary and reasonable legal skills andknowledge and was therefore guilty of negligence and/or wantonness in that they failedto preserve the Plaintiff’s potential claims and litigate those claims as an ordinary andprudent attorney.

50. The Defendants made oral and written statements of material facts as well assuppressed material facts with the intent of deceiving and defrauding the Plaintiff. 51. On or about the 12 day of January 2012, Plaintiff became aware for the first timeth

of certain facts that made Plaintiff aware that Defendants had not performed their dutiesin the same manner as an attorney in Alabama who possessed and exercised ordinary andreasonable legal skills and knowledge. 52. As a proximate result of the Defendants’ said negligence and/or wantonness, thePlaintiff was caused to suffer economic damages, mental anguish and emotional distress. 53. Plaintiff claims punitive damages of Defendants because of the Defendants’wanton misconduct.

JURY DEMAND

54. Plaintiff demands trial by a struck jury of all issues so triable in this case.

DEMAND

55. The Plaintiff requests compensatory and punitive damages against the Defendantsto be determined by a jury including but not limited to economic damages, mentalanguish and any other remedies available under Alabama Law.

This the 1 day of March, 2012.st

/s/ Clint Mountain Clint Mountain (MOU-012)

/s/ C. Delaine Mountain C. Delaine Mountain (MOU-002)

OF COUNSEL:MOUNTAIN, BAIRD & MOUNTAINP.O. Box 2885Tuscaloosa, AL 35403(205) 349-1740 - phone(205) 349-1762 - facsimile

Defendants’ Service Addresses:

Byron E. House5809 Harborview LaneNorthport, AL 35473

Bobby Cockrell, Jr. andCOCKRELL and COCKRELL1409 University Blvd.Tuscaloosa, AL 35401

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)vs. )


Defendants. )

PLAINTIFFS NOTICE OF DEPOSITION AND REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT BYRON E. HOUSE

Please take notice that the deposition of BYRON E. HOUSE will be taken at a

mutually agreed time and place.

This deposition will be taken upon oral examination before a notary public or

before some other officer authorized by law to administer oaths, for the purpose of

discovery, or for the use as evidence in this action, or for both purposes, pursuant to the

Alabama Rules of Civil Procedure. The oral examination will continue from time to

time until completed. You are invited to attend and cross-examine the witness.

Pursuant to Alabama Rules of Civil Procedure 30(b)(5), Plaintiff requests that

Defendant BYRON E. HOUSE produce and permit Plaintiff to inspect and copy each

of the following documents:

(a) any and all files, memorandums or documents that pertain to the above-

styled cause of action;

In answer to the above request for production of documents, you are required to

furnish all documents available to you, including documents in the possession of your

attorney or any person acting on your behalf. If you cannot locate any particular




document, after exercising due diligence to secure the document sought, so state in

your answer, specifying your inability to locate the document and the last known

person having custody of such document.

You are under a duty to seasonably amend a prior response if you obtain

information upon the basis of which (a) you know that the response was incorrect when

made, or (b) you know that the response, though correct when made, is no longer true,

and the circumstances are such that a failure to amend the response is, in substance, a

knowing concealment.

Any supplemental responses should be filed and served upon counsel for the

Plaintiff within fifteen (15) days after receipt of such information.

You are further advised that other parties to the action in which this subpoena

has been issued have the right to be present at the time of such production or

inspection. You have the right to object at any time prior to the date set forth in this

subpoena for compliance. Should you choose to object, you should communicate such

objection in writing to the party causing the issuance of this subpoena and stating, with

respect to any item or category to which objections are made and your reasons for such

objection.

This the 1st day of March 2012.

/s/ Clint Mountain ____________________ Clint Mountain (MOU-012)

/s/ C. Delaine Mountain_________________ C. Delaine Mountain (MOU-002)







)vs. )


Defendants. )

PLAINTIFFS NOTICE OF DEPOSITION AND REQUEST FOR PRODUCTION OF DOCUMENTS

TO DEFENDANT BOBBY COCKRELL, JR.

Please take notice that the deposition of BOBBY COCKRELL, JR. will be

taken at a mutually agreed time and place.

This deposition will be taken upon oral examination before a notary public or

before some other officer authorized by law to administer oaths, for the purpose of

discovery, or for the use as evidence in this action, or for both purposes, pursuant to

the Alabama Rules of Civil Procedure. The oral examination will continue from time

to time until completed. You are invited to attend and cross-examine the witness.

Pursuant to Alabama Rules of Civil Procedure 30(b)(5), Plaintiff requests that

Defendant BOBBY COCKRELL, JR. produce and permit Plaintiff to inspect and copy

each of the following documents:

(a) any and all files, memorandums or documents that pertain to the above-

styled cause of action;

In answer to the above request for production of documents, you are required

to furnish all documents available to you, including documents in the possession of

your attorney or any person acting on your behalf. If you cannot locate any particular




document, after exercising due diligence to secure the document sought, so state in

your answer, specifying your inability to locate the document and the last known

person having custody of such document.


information upon the basis of which (a) you know that the response was incorrect

when made, or (b) you know that the response, though correct when made, is no

longer true, and the circumstances are such that a failure to amend the response is, in

substance, a knowing concealment.

Any supplemental responses should be filed and served upon counsel for the

Plaintiff within fifteen (15) days after receipt of such information.

You are further advised that other parties to the action in which this subpoena

has been issued have the right to be present at the time of such production or

inspection. You have the right to object at any time prior to the date set forth in this

subpoena for compliance. Should you choose to object, you should communicate such

objection in writing to the party causing the issuance of this subpoena and stating, with

respect to any item or category to which objections are made and your reasons for such

objection.










)vs. )


Defendants. )

30(b)(5) and (6) DEPOSITION NOTICE FOR REPRESENTATIVE OF DEFENDANT COCKRELL AND COCKRELL

AND REQUEST FOR PRODUCTION OF DOCUMENTS

Please take notice that at a mutually agreed time and place, counsel for Plaintiff, pursuant to Alabama Rules of Civil Procedure Rule 30(b)(5) and (6), will take the deposition upon oral examination of Defendant Cockrell and Cockrell, through the testimony of one or more officers, directors, employees, or agents who has the most knowledge regarding of DCH’s knowledge regarding the following:

1.

Such testimony by deposition will be taken by agreement of the parties on a date and at a time to be determined later as agreed upon by the parties before Tuscaloosa Court Reporting or other officer authorized to administer oaths and may be continued from time to time. You are invited to attend and cross examine. Pursuant to Alabama Rules of Civil Procedure 30(b)(5), Plaintiff requests that Defendant Cockrell and Cockrell and or deponent produce and permit Plaintiff to inspect and copy each of the following documents:

(a) any and all files, memorandums or documents that pertain to the above-styled cause of action;

(b) any and all documents concerning the plaintiff.

In answer to the above requests for production of documents, you are required to furnish all documents available to you, including documents in the possession of your attorney or any person acting on your behalf. If you cannot locate any particular document, after exercising due diligence to secure the document sought, so state in your answer, specifying your inability to locate the document and the last known person having custody of such document.





information upon the basis of which (a) you know that the response was incorrect when made, or (b) you know that the response, though correct when made, is no longer true, and the circumstances are such that a failure to amend the response is, in substance, a knowing concealment.

Any supplemental responses should be filed and served upon counsel for the Plaintiff within fifteen (15) days after receipt of such information.

You are further advised that other parties to the action in which this subpoena has been issued have the right to be present at the time of such production or inspection. You have the right to object at any time prior to the date set forth in this subpoena for compliance. Should you choose to object, you should communicate such objection in writing to the party causing the issuance of this subpoena and stating, with respect to any item or category to which objections are made and your reasons for such objection.




OF COUNSEL:MOUNTAIN, BAIRD & MOUNTAINP.O. Box 2885Tuscaloosa, AL 35403(205) 349-1740 - phone(205) 349-1762 – facsimile






)vs. )


Defendants. )

PLAINTIFF'S REQUESTS FOR PRODUCTION TO DEFENDANTS

COMES NOW the Plaintiff by and through her counsel of record and pursuant to Rules 33 and 34 of the Alabama Rules of Civil Procedure, propounds the following discovery to be answered in the time allowed by law:

DEFINITIONS

A. "You" or "Your" refers to the party to whom this request is directed.

B. "Document(s)" is used in its broadest possible sense and shall mean: any written, printed, typed, recorded, computerized, electronic or other graphic matter of every kind and nature; all mechanical and electrical or electronic sound recordings and any transcripts thereof; photographs or drawings; internal or external memorandums and correspondence; electronic or other calendars, diaries and e-mails, e-mail in-box, deleted or outbox lists and substantive e-mail messages; and all computer data files in your possession, custody, and/or control, or known to you to exist. This definition of "document" includes, without limitation: all preliminary documents, all copies of documents, all marginal or other notes on documents or copies thereof, all file folders, and all labels or markings indicating the manner in which the documents have been maintained.

C. "Relating to" or "regarding" as used herein means and includes: referring to, commenting on, connected with, bearing on, leading to, dealing with, evidencing, discussing, covering, representing or mentioning, in any way whatsoever, directly or indirectly.

D. "Surrounding" as used herein means and includes: before the period at issue, during the period at issue, and after the period at issue.

E. "Identify" as used herein with reference to an individual, person, corporation, or other entity, means to state his, her or its: (1) full name; (2) present or last known business and residence addresses; 3) present or last known business and home phone




numbers; and (4) present or last known position, business affiliation, employer, and title.

F. "Or" as used herein should not be read so as to eliminate any part of any request, or as permitting the option of responding to any part of any request by answering as to only one of the terms separated by "or;" rather, whenever applicable, "or" should be read as having the same meaning as the word “and.”

G. “Writing” as used herein includes the original or copy of handwriting, typewriting, printing, photostatting, photographing, and every other means of recording upon any tangible thing, any form of communication or representation, including letters, words, pictures, sounds, and symbols, or combinations of them.

H. "Possession", as used herein, means physical possession, implicit possession or legal possession. For example, if a third party holds documents for this defendant, that would still qualify as "legal" possession.

INSTRUCTIONS

A. Pursuant to the applicable rules of civil procedure, these discovery requests must be completed within the applicable time frame. Failure to comply with such time frame will result in a motion to compel being filed by Plaintiff(s).

B. If a privilege not to answer a request for production is claimed, identify each document or response as to which the privilege is claimed, the nature of the privilege, and the legal and factual basis for each such claim.

C. If a refusal to produce a particular document is burdensome, identify the document(s) needed to be searched, the location of the document(s), and identify each person(s) or entity that must be consulted.

SUPPLEMENTATION OF RESPONSES

These requests for production are of an ongoing nature, and should you acquire additional information or documents responsive to these requests, such answers to these requests shall be supplemented to include the additional information or documents pursuant to Rule 26(e) and/or 26(f) of the Rules of Civil Procedure.

SPECIFIC REQUESTS

1. Any and all statements, correspondence, memoranda, writings or other documents prepared by the defendant attorney and/or any other attorney, employee, agent or representative of the defendant law firm concerning the claims of the Plaintiff.

2. All files, documents or data by any medium in the defendant attorney or law firm’s possession in connection with any work performed for or on behalf of the Plaintiff.

3. The entire files of the Plaintiff, including writings, correspondence, memoranda, or any other document concerning the claims detailed in the Plaintiff’s complaint.

4. Copies of any and all correspondence, writings, reports, CVs or documents from any consulting expert hired by the defendant attorney or law firm in connection with the underlying lawsuit.

5. Copies of any and all correspondence, writings, reports or documents from any consulting expert hired by the defendant attorney or law firm in connection with this lawsuit.

6. The expert reports of any expert witnesses who will be called to testify by defendant in this cause. If such expert has not prepared a report, then request is hereby made that the expert's findings and opinions be reduced to writing in the form of a report and produced.

7. All photographs, videotapes and/or other photographic reproductions which may be used in the trial of this cause.

8. A copy of all documents relating to any grievance filed by the plaintiff against the defendant attorney or law firm, including the defendant attorney's response to such complaint.

9. A copy of the Curriculum Vita of any expert which you expect to testify in this case.

10. A copy of the defendant attorney's annual audits submitted to any legal specialization board, as well as the original application for certification as a specialist.

11. A copy of the defendant attorney's minimum continuing legal education records of attendance at seminars during the preceding five years.

12. A copy of all canceled checks or other documents reflecting any and all income received by the defendant attorney or law firm in connection with the underlying case, as well as copies of expenses paid by the defendant attorney or law firm.

13. A copy of any contracts between defendant attorney and the client in the underlying case.

14. A copy of any correspondence including attachments or materials provided to the Alabama State Bar regarding any complaints against the Defendants.

15. A copy of any materials received from any party via request or subpoena in this action or any related action.

16. Any and all insurance or other casualty coverage that potentially covers any potential damages arising from this case, whether or not coverage is disputed (declaration pages of any potential coverages will suffice.)

Dated this the 1st day of March 2012.



OF COUNSEL:MOUNTAIN, BAIRD & MOUNTAINP.O. Box 2885Tuscaloosa, AL 35403(205) 349-1740 - phone(205) 349-1762 – facsimile




Documents

NOTICE OF ELECTRONIC FILING - Lawyers USA OnlineAlaFile E-Notice To: CLINT MOUNTAIN [email protected] 63-CV-2012-900178.00 NOTICE OF ELECTRONIC FILING IN THE CIRCUIT COURT OF TUSCALOOSA