ed-1o 101 fast Print ANU WM IN THE DISTRICT COURT OF OKLAHOMA COUNTY erOserVO78 9s STATE OF OKLAHOMA JONATHAN DUGGAN, ) ) Plaintiff, ) ) vy. } Case No, ) - ae ONE GAS, INC. d/b/a OKLAHOMA) Cy 2016 1 901 NATURAL GAS, ) ) ORLY DISTRICT coy Defendant. ) OMA co} URT PETITION APR LL 2015 TIM RHO; COUNTI DES COUNTI 7 COURT CLERS Plaintiff states: een, 1. On January 2, 2016, at approximately 3:15 am., Plaintiff Jonathan Duggan (“Plaintiff”) was asleep in his bedroom at 12505 Whispering Hollow Drive in Oklahoma City, ‘Oklahoma, Oklahoma County when the house exploded duc to a leak of natural gas. 2, The explosion resulted from the negligence of Defendant as follows: a. Defendant failed to inspect the aforementioned area at a time when Defendant knew, or should have known, that without said inspection persons, including Plaintiff, were likely to be injured. b. Defendant failed to maintain the aforementioned area at a time when Defendant knew, or should have known, that without said maintenance persons, including Plaintiff, were likely to be injured. ¢. Defendant failed to remove the dangerous condition from the aforementioned area at a time when Defendant knew, or should have known that without removing said dangerous condition persons, includingPlaintiff, were likely to be injured. 4. Defendant failed to war persons, including Plaintiff, of the dangerous condition from the aforementioned area at a time when Defendant knew, or should have known, that without said waming persons, including Plaintiff, were likely to be injured. ¢. Defendant created a hazard known to Defendant at a time when Defendant knew or should have known that said hazard was likely to cause injuries to persons, including Plaintiff. 3. At all times mentioned herein, Defendant acted through its employees and/or agents, known to Defendant and unknown to Plaintiff, and said employees and/or agents were acting within the scope and course of their employment and agency. 4, Asa result of Defendant's negligence, Plaintiff suffered personal injuries. Said injuries are permanent, painful, progressive and disfiguring. When injured, Plaintiff was 29 years old with a life expectancy of 48,69 more years. Plaintiff has and will incur medical bills, has and will suffer pain of mind and body, has and will lose income and is permanently disfigured, damaging Plaintiff in an amount in excess of $75,000.00. COUNT HL 5, Plaintiff for Count Il repleads and realleges the allegations of Count I herein and states as a further result of Defendants negligence, Plaintiff's personal property was destroyed and/or damaged, which caused Plaintiff damages in an amount in excess of $75,000.00.COUNT 1 6. Plaintiff for Count III repleads and realleges the allegations of Count J-II herein and states the acts of Defendant were gross, wanton, willful and/or intentional for which punitive damages should be assessed in an amount in excess of $75,000.00. WHEREFORE, Plaintiff prays judgment against Defendant in an amount in excess of $75,000.00, together with attomey fees, interest and costs of this action. ATTORNEYS’ LIEN CLAIMED T. LUKE ABEL, OBA21094 DACIA ABEL, OBA #30968 ABEL LAW FIRM 900 N.E. 63" Street Oklahoma City, OK 73105 (405) 239-7046 (405) 418-0833 (fax) Jabel@abellawtirm.com dabel@abellawfirm.com ATTORNEYS FOR PLAINTIFF