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BYRD
CUYAHOGA COUNTY CUERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
vs.
Judge: PAMELA A BARKER
CUYAHOGA COUNTY BOARD OF
COMMISSIONERS, ET AL.
Pages Filed: 29
and )
)
Defendants.
Administrator for the Estate of TaNaejah McCloud, by and through their attorneys, THE
DERATANY FIRM and OBRAL, SILK & ASSOCIATES, LLC, and for their Complaint against
INTRODUCTION
Ta’Naejah McCloud and Shabrina McCloud for the loss of Ta’Naejah McCloud, who was a
developmentally disabled five (5) year old child who required close oversight, attention and
unconscionable abuse both psychological and physical at the hands of her mother, Tequila
Crump and her live-in girlfriend, Ursula Owens, both named defendants herein. This abuse
resulted in the tragic death of Ta’Naejah on March 19, 2017, caused by, inter alia, the conduct
of these defendants.
3. The cause of death was determined to be blunt force injuries and the manner of
death was homicide following significant professional neglect by the defendant, Department of
Children Family Services. Five year old Ta’Naejah was brutally killed while those responsible
for protecting her either looked away or looked on and did nothing.
4. This action seeks to hold accountable the defendants who are the individuals,
professionals and the public and private agencies charged with protecting, investigating and
ensuring the safety, and providing necessary services to the family and this precious child. The
defendants, individually and collectively, turned a blind eye to clear and present indications of
ongoing physical abuse and neglect, acting indifferently to Ta’Naejah’s safety and well-being
and blatantly failing her, leaving her exposed to longstanding and continuing harm and
investigation requirements to protect children from neglect and abuse, were grossly reckless in
their duties, and acted in contravention of reasonable standards of care and practice.
McCloud (age 5), became severely physically abused, brain dead and died on March 19, 2017.
8. This action seeks remedies for her harm and losses against the culpable parties,
whose actions and inactions violated the letter of the law, ignored professional standards, and
manifested an unforgivable and reckless indifference for the safety and health of this most
vulnerable disabled child. This action seeks compensatory and, where appropriate, punitive
damages for the horrific harms done to Ta’Naejah and her preventable death.
PARTIES
"Ta’Naejah") resided at 10722 Bryant Ave, Cleveland, Cuyahoga County, Ohio 44108, and
other unknown addresses with her mother, Tequila Crump and Mother’s partner, Ursula
11. Kevin Lipman was appointed on September 25, 2018 as administrator of the
Estate of Ta’Naejah McCloud, in The Court of Common Pleas of Cuyahoga County, Ohio,
12. At all times relevant herein, the Defendant CUYAHOGA COUNTY BOARD OF
COMMISSIONERS, was and is a political subdivision in and for the County of Cuyahoga, State
of Ohio, that employed social workers, case managers and case workers who provided social
services that included, but were not limited to, foster care placement and implementation,
FAMILY SERVICES (hereinafter “CCDCFS”) is a public social services agency charged with
serving individuals and families in Cuyahoga County and providing them services that enhance
the quality of family life. Specifically, CCDCFS is a child protection agency charged with
providing social services to children which promote a child’s right to safety and stability, as well
14. CCDCFS employees and social workers also manage a 24-hour hotline/Intake
department that is charged with investigating child abuse and neglect; referring children and
families to services; and protecting children who are at risk of harm and cannot remain in their
homes.
15. John/Jane Doe I-VII were, at all times relevant, social workers employed by
CCDCFS operating in the course and scope of their employment and had a statutory duty to
record abuse and neglect, investigate reported abuse and neglect, conduct and complete safety
child who is in danger of abuse. Plaintiff cannot identify said social workers by name because
records of their identity are maintained in the control and custody of Defendant CCDCFS and
are not available and cannot be discovered by the plaintiffs prior to the filing of the within
action.
16. Defendant, Kristina Quint, was at all times relevant herein, a social worker
employed by CCDCFS operating in the course and scope of her employment and was
responsible for screening and investigating claims of child abuse and neglect and protecting
children at serious risk of harm, conduct and complete a safety assessment, conduct face to face
interviews of the alleged child victim of child abuse or neglect, refer and recommend removal
of child victim from unsafe environment, initiate emergency removal proceedings to protect the
child victim. Specifically, Kristina Quint was charged with screening and investigating claims
for suspicion of neglect and abuse lodged in September, 2016, early in October, 2016 and mid
17. Defendant, Ada Jackson, was, at all times relevant, a social worker employed by
CCDCFS operating in the course and scope of her employment and was responsible for
screening and investigating claims of child abuse and neglect, conduct face to face interview of
child victim, protecting children at serious risk of harm, conduct and complete safety
assessment, refer and recommend removal of child victim from home, initiate emergency
removal proceedings to protect the child victim. Specifically, Ada Jackson was charged with
screening and investigating claims of neglect and abuses lodged in February 2017 through
18. Defendant, Marquetese Betts, was at all times relevant herein, a social worker
was responsible for supervising the screening and investigations of claims of child abuse and
neglect, conduct and complete a safety assessment plan, refer and recommend removal of child
victim from home that is unsafe, initiate emergency removal proceedings to protect the child
victim. Specifically Marquetese Betts was charged with supervising the screening and
investigation of claims of abuse and neglect lodged in February, 2017, through March 17, 2017,
related to Ta’Naejah McCloud, and had responsibility to act and remove a child who is in an
unsafe environment.
natural mother of Ta’Naejah McCloud, who, at all times relevant, resided in Cuyahoga County
and who was convicted in the death of Ta’Naejah McCloud, more specifically convicted of
multiple counts of Reckless Homicide, multiple counts of Endangering Children, and was
20. Defendant, Ursula Owens, was the live-in girlfriend/partner of Tequila Crump
who, at all times relevant herein, resided in Cuyahoga County and who was convicted in the
Reckless Homicide, Felonious Assault and multiple counts of Endangering Children and was
21. Decedent Ta’Naejah McCloud was born September 2, 2011, to Tequila Crump,
23. At the time of her birth, Ta’Naejah lived in Lynchburg, VA, with her biological
25. Shabrina named Ta’Naejah and Ta’Naejah carried her last name.
26. At or about June 2016, defendant, Tequila Crump moved in with defendant
27. On or about June 2016, and continuing to her death, Tequila Crump and Ursula
28. In October 2016, CCDCFS was aware and had knowledge of several reported
cases of abuse and neglect related to Ta’Naejah but failed or refused to investigate the
allegations.
29. Between 2016-2017, the above stated CCDCFS social workers were contacted
by neighbors and /or medical providers about abuse and injury to report suspected abuse and
30. On or about September 2016, it was reported to CCDCFS social worker that
Tequila Crump and Ursula Owens were burning Ta’Naejah well before her hospitalization for
third degree burns. CCDCFS through its social worker, deliberately refused to investigate the
31. On or about early October 2016, it was reported to CCDCFS that Ta’Naejah was
being beaten and punched in her face by defendants, Tequila Crump and her girlfriend Ursula
Owens. CCDCFS failed to properly investigate these allegations of abuse and neglect.
32. On or about October 17, 2016, Ta’Naejah was taken to University Hospitals
CCDCFS that these burns may not have been self - inflicted as reported by Tequila Crump and
Ursula Owens, but in fact, were the result of abuse. CCDCFS failed to assess and investigate
these burns.
33. On or about October 18, 2016, Ta’Naejah was transferred to Metro Health
Medical Center Burn Intensive Care Unit. She was admitted with third degree burns on the
back of her hands and all of her fingers. CCDCFS failed to properly investigate these burns.
34. Ta’Naejah was required to undergo painful grafting surgery as a result of the
third degree burns. The surgery was performed by Dr. Yowler. Dr. Yowler reported to the
Metro Health social worker that he did not believe the burns were self- inflicted. This
information was reported to CCDCFS social worker Kristina Quint who failed to investigate
and failed to act to remove Ta’Naejah from the home of Tequila Crump and Ursula Owens.
35. It was reported to Kristina Quint that a Metro Health nurse suspected abuse and
36. It was reported to Kristina Quint by nursing staff that Ta’Naejah said she was
scared of the hot water and went to the bathroom with her mom. Kristina Quint failed to
investigate or interview Ta’Naejah alone, or assess the risk posed to Ta’Naejah if she returned
37. Metro Health social worker Kathy Mahoney called CCDCFS several times
throughout the admission of Ta’Naejah and reported to CCDCFS that the burn injuries were
suspicious injuries that call for further investigation. CCDFCS failed to investigate either the
burns or that TaNaejah was not enrolled in school. CCDCFS failed to remove Ta’Naejah from
the home.
the burn injury reported by Metro Health and RBC. She only came to the hospital one time and
Kathryn Mahoney discussed her concerns and provided Quint with clinical documentation that
was needed, which supported her concern for the need for investigation. Kristina Quint failed
to investigate the abuse and neglect, failed to report this conduct and failed to act to remove
39. Kristina Quint failed to investigate the issue with hot water, and interview the
nurses or doctors who treated Ta’Naejah. She failed to go to the house and interview the other
40. Kristina Quint did not interview the landlord concerning the hot water. She
never interviewed Rayvon Owens. She never investigated the temperature of the hot water.
41. After failing to investigate the reported abuse and neglect of Ta’Naejah,
Kristina Quint and her CCDCFS supervisors made the decision to release Ta’Naejah to her
mother upon discharge from the hospital. The assessment/investigation, was not timely
42. After Ta’Naejah’s discharge from the hospital in October 2016 through
February 2017 multiple complaints of neglect and/or abuse were made to CCDCFS and none of
43. In February, 2017, a county social worker reported to CCDCFS that Ta’Naejah
was being physically abused. A case was opened and Ada Jackson was responsible for
investigating the report. CCDCFS failed to properly investigate this report and failed to remove
investigate further and/or remove Ta’Naejah from the home in February, 2017.
45. From February 7, 2017, through March 17, 2017, a number of complaints were
made to CCDCFS concerning allegations of physical abuse. CCDCFS was aware of these
reports and failed to investigate and remove Ta’Naejah from the home.
46. It was discovered by Ada Jackson that Ta’Naej ah was sleeping on the floor with
no pillow and no blanket and had no bed during February 2017 - March 17, 2017. They did
47. During February, 2017, through March, 2017, CCDCFS was aware that
Ta’Naejah was in a home infested with bed bugs and cockroaches. It was reported to CCDCFS
that Ta’Naejah was eating cockroach-filled sandwiches and CCDCFS failed to investigate these
48. On March 16, 2017, the day before the brutal physical abuse of Ta’Naejah that
resulted in her death, Defendants Crump and Owens made Ta’Naejah scrub the floor with a rag
soaked in bleach and Ta’Naejah was consumed by the aroma of the bleach, and blacked out.
This was punishment for accidently urinating on herself. CCDCFS had an open case on
Ta’Naejah during this time period and failed to investigate this abuse and failed to remove
49. Sometime between February 7, 2017, through March 17, 2017, Ta’Naejah was
examined by a physician. Ada Jackson was present and it was discovered and reported to Ms.
Jackson that Ta’Naejah had multiple scars on her body and that she had only gained one pound
in the last four to five months, since October, 2016. The Physician indicated to Ms. Jackson
Defendants Crump and Owens, and failed to investigate the scarring on her body.
50. At some point on or after February 7, 2017, and prior to the death of Ta’Naejah,
Defendant Crump reported to CCDCFS that she was suffering from mental health issues and
51. Marquetese Betts determined that the risk level for Ta’Naejah was high and kept
her case open as a result of the February 7, 2017 physical abuse report, but took no further
action.
52. Marquetese Betts congratulated Defendant Crump for requesting mental health
services but failed to remove Ta’Naejah from the home given the unsafe/unstable mental
53. From September, 2016, through March, 2017, Defendant Owens would
repeatedly punch and violently push Ta’Naejah to the ground. Owens would use her hands,
fists, belts, and other objects to strike Ta’Naejah. These acts were witnessed by neighbors,
family members, and other individuals living in the home. These events were reported to
CCDCFS and CCDCFS failed or refused to investigate these reports and/or remove the
54. Between February, 2017, and March, 2017, prior to her death, Ta’Naejah
suffered a fractured clavicle and multiple rib fractures. CCDCFS failed or refused to investigate
55. On March 17, 2017, at approximately 10:00 A.M., while in the care of CCDCFS
and being monitored by CCDCFS, Defendant Crump repeatedly struck Ta’Naejah and stood by
and watched Defendant Owens throw Ta’Naejah against the wall, the dresser and floor.
approximately 10:00 A.M. Ursula Owens began yelling at Ta’Naejah, hit her multiple times,
picked her up and threw her against the wall, threw her against the dresser, threw her to the
unresponsive at the home of Defendants Crump and Owens, yet they refused to call for medical
assistance.
58. At approximately 10:00 P.M. that evening on March 17, 2017, Ta’Naejah was
rushed to the emergency room, where she was examined, tested and determined to have
59. Ta’Naejah succumbed to her injuries and died on March 19, 2017.
60. An autopsy performed on March 20, 2017, concluded that the cause of death of
Ta’Naejah McCloud was, “multiple blunt force injuries” and the manner of death was quickly
determined to be homicide.
61. At all times relevant, Ta’Naejah was living with her custodial biological mother
Tequila Crump and her girlfriend Ursula Owens both named defendants herein. Tequila Crump
was arrested and charged, and convicted by a jury of reckless homicide and endangering
children, as a result of the events which led to the death of Ta’Naejah McCloud. Ursula Owens
was convicted by a jury of Murder, Reckless Homicide, Endangering Children and Felonious
Assault as a result of the events which led to the death of Ta’Naejah McCloud.
62. Cuyahoga County public agencies had known of the abuse and neglect
63. Cuyahoga County public agencies were aware that defendants, Crump and
2017, they witnessed the abuse up close and personal when it was determined that Ta’Naejah
was malnourished and underweight, not in school and had a developmental delay.
64. CCDCFS failed to investigate all the above-referenced complaints and declined
to investigate and take immediate action to ensure the health and safety of Ta’Naejah by
65. Ada Jackson, Marquetese Betts, Kristina Quint and John/Jane Does I-VII were
the individuals responsible for investigating suspicions of child abuse and neglect and
protecting children who are at serious risk and whose failure to respond and investigate such
complaints was reckless and indifferent to the known and obvious risks facing Ta’Naejah.
66. Over the course of these many months, the condition and health of Ta’Naejah,
including her physical appearance and assessments, continued to decline such that a reasonable
person in a similar position would have suspected physical abuse and neglect.
67. Plaintiffs KEVIN LIPMAN and SHABRINA McCLOUD, restates and incorporates
by reference, Paragraphs 1 through 66 of this Complaint at Law as and for Paragraphs 1 through
O.R.C. 2151.421, Cuyahoga County Board of Commissioners and CCDCFS through its
agents/employees were required to comply with regulations, in providing social services and
investigating child, neglect and abuse to children under the age of 18 years who had suffered or
faced the threat of suffering injury, disability or a condition of a nature that reasonably
69. On or about September, 2016, and continuing to her death, Cuyahoga County
Board of Commissioners and CCDCFS owed a duty to Ta’Naejah pursuant to Ohio Revised
Code and OAC regulations requiring CCDCFS to provide care and services to Ta’Naejah.
70. At all times from September 2016 up through March 17, 2017, Defendants had a
common law duty, as well as a statutory duty, and a duty pursuant to its voluntary undertaking,
to protect the health, safety and best interests of Ta’Naejah in all situations in which she was
vulnerable to child abuse or neglect, offer protective services in order to prevent any further
harm to Ta’Naejah and to provide recommendations and services which will stabilize the home
Children Family Services through its employees breached its duty of care that was owed to
c) From February 2017 through March 17, 2017, failed to visit; and
monitor the home of Ta’Naejah, failed to provide necessary living
essentials to Ta’Naejah ie. Food, bed, failed to remove Ta’Naejah
from a cock roach and bed bug infested home, failed to remove
d) From February 2017 through March 17, 2017 failed to assess the
mental health of Tequila Crump after learning that Tequila had
mental health issues; and failed to act to remove Ta’Naejah from
the home;
e) From September 2016 through March 17, 2017 failed to assess the
mental health and failed to evaluate the risk and assess whether
defendant Owens was a safety concern for Ta’Naejah despite
previous allegations of abuse directed toward Rayvon Owens,
abuse known to CCDCFS that resulted in the removal of her own
biological children;
72. As a direct and proximate result of one or more of the aforesaid acts or
administrator of the Estate of Ta’Naejah McCloud, Deceased, brings this wrongful death
74. That on or about March 19, 2017, Ta’Naejah McCloud left surviving her:
All the above have suffered pecuniary loss, including grief and sorrow and loss of society
WHEREFORE, Plaintiffs prays for judgment against each Defendant, jointly and
cause of action in this complaint, as well as other appropriate relief, including attorney’s fees
and litigation expenses, the costs of this action, pre and post judgment interest, and any other
legal, equitable, injunctive or declaratory relief that may be just and appropriate.
employees of CCDCFS was required to comply with regulations, in providing social services
and investigating child, neglect and abuse to children under the age of 18 years who had
suffered or faced the threat of suffering injury, disability or a condition of a nature that
77. On or about September 2016, and continuing to her death these Defendants
owed a duty to Ta’Naejah pursuant to Ohio Revised Code and regulations requiring social
78. At all times from September, 2016, up through March 17, 2017, Defendants had
a common law duty, as well as a statutory duty, and a duty pursuant to its voluntary
undertaking, to protect the health, safety and best interests of Ta’Naejah in all situations in
which she was vulnerable to child abuse or neglect, offer protective services in order to prevent
any further harm to Ta’Naejah and to provide recommendations and services which will
stabilize the home environment and preserve the life of the child.
79. Defendants Kristina Quint, Ada Jackson, Marquetese Betts, John/Jane Does I-
VII breached its duty of care that was owed to Ta’Naejah by one or more of the following acts:
c) From February, 2017 through March 17, 2017, failed to monitor the
home of Ta’Naejah, failed to provide necessary living essentials to
Ta’Naejah ie. Food, bed, failed to remove Ta’Naejah from a cock
roach and bed bug infested home, failed to remove Ta’Naejah from
an unsafe and unsanitary living situation;
d) From February 2017 through March 17, 2017 failed to assess the
mental health of Tequila Crump after learning that Tequila had
mental health issues and failed to act to remove Ta’Naejah from the
home;
e) From September 2016 through March 17, 2017 failed to assess the
mental health and failed to evaluate the risk and assess whether
Ursula was a safety concern for Ta’Naejah despite previous
allegations of abuse directed toward Rayvon Owens, abuse known
to the defendants that resulted in the removal of her own biological
children;
80. As a direct and proximate result of one or more of the aforesaid acts or
omissions, Ta’Naejah McCloud, sustained injuries resulting in her death on March 19, 2017
administrator of the Estate of Ta’Naejah McCloud brings this wrongful death action, pursuant
to O.R.C. §2125.02.
82. That on or about March 19, 2017, TaNaejah McCloud left surviving her:
All the above have suffered pecuniary loss, including grief and sorrow and loss of society
WHEREFORE, Plaintiffs prays for judgment against each Defendant, jointly and
cause of action in this complaint, punitive damages where permissible and appropriate in an
attorney’s fees and litigation expenses, the costs of this action, pre and post judgment interest,
and any other legal, equitable, injunctive or declaratory relief that may be just and appropriate.
O.R.C. 2151.421, DCFS through its agents/employees was required to comply with regulations,
in providing social services and investigating child, neglect and abuse to children under the age
of 18 years who had suffered or faced the threat of suffering injury, disability or a condition of
85. After February 7, 2017, DCFS owed a duty to Ta’Naejah pursuant to Ohio
Revised Code and regulations requiring CCDCFS to provide care and services to Ta’Naejah
after keeping her case open in February 2017 and continuing to maintain contact and refer
Ta’Naejah and her family to private providers to provide medical services and care to
86. At all times from September 2016 up through March 17, 2017, Defendants had a
common law duty, as well as a statutory duty, and a duty pursuant to its voluntary undertaking,
to protect the health, safety and best interests of Ta’Naejah in all situations in which she was
vulnerable to child abuse or neglect, offer protective services in order to prevent any further
harm to Ta’Naejah and to provide recommendations and services which will stabilize the home
Department of Children and Family Services, through its employees, breached its duty of care
c) From February 2017 through March 17, 2017, failed to monitor the
home of Ta’Naejah, failed to provide necessary living essentials to
Ta’Naejah ie. Food, bed, failed to remove Ta’Naejah from a cock
roach and bed bug infested home, failed to remove Ta’Naejah from
an unsafe and unsanitary living situation;
d) From February 2017 through March 17, 2017 failed to assess the
mental health of Tequila Crump after learning that Tequila had
mental health issues; Failed to act to remove Ta’Naejah from the
home as a result of mental health issues;
e) From September 2016 through March 17, 2017 failed to assess the
mental health and failed to evaluate the risk and assess whether
Ursula was a safety concern for Ta’Naejah despite previous
allegations of abuse directed toward Rayvon Owens, abuse known
to CCDCFS that resulted in the removal of her own biological
children;
88. As a direct and proximate result of one or more of the aforesaid acts or
omissions, Ta’Naejah McCloud, sustained injuries resulting in her death on March 19, 2017
administrator of the Estate of Ta’Naejah McCloud brings this wrongful death action, pursuant to
O.R.C. §2125.02.
90. That on or about March 19, 2017, TaNaejah McCloud left surviving her:
All the above have suffered pecuniary loss, including grief and sorrow and loss of society
WHEREFORE, Plaintiffs prays for judgment against each Defendant, jointly and
cause of action in this complaint, as well as other appropriate relief, including attorney’s fees
and litigation expenses, the costs of this action, pre and post judgment interest, and any other
legal, equitable, injunctive or declaratory relief that may be just and appropriate.
92. This cause of action is brought against ADA JACKSON, KRISTINA QUINT,
MARQUETESE BETTS, JOHN/JANE DOES I-VII and other employees of Cuyahoga County
under the theory of respondeat superior for their reckless conduct undertaken within the scope
of their employment or official responsibilities with the Cuyahoga County CCDCFS, such that
one or both political subdivisions shall indemnify them in the amount of any judgment rendered
on this claim.
93. Ada Jackson, Kristina Quint, Marquetese Betts, John/Jane Does I-VII and other
employees, were reckless in that their conduct was characterized by a conscious disregard or
indifference to the known and obvious risk that Ta’Naejah was being neglected, was not
receiving appropriate and necessary medical services and/or malnourished, neglected, and/ or
physically abused. The conduct of Kristina Quint, Ada Jackson, Marquetese Betts and other
danger presented by the reports of physical abuse, neglect, and visible signs of malnourishment,
the conditions of the Crump-Owens home, as well as documented reports of suspected neglect,
94. Ada Jackson, Kristina Quint, Marquetese Betts, John/Jane Does I-VII and other
employees, exhibited a conscious disregard for the rights and safety of Ta’Naejah despite a
great probability that substantial harm would result from such failures.
95. As a direct and proximate result of the reckless conduct of Ada Jackson,
Kristina Quint, Marquetese Betts, John/Jane Doe I-VII and other employees, Ta ’Naejah
suffered harms, losses and a wrongful death for which these political subdivisions are
vicariously liable.
administrator of the Estate of Ta’Naejah McCloud, prays for judgment against each Defendant,
on each cause of action in this complaint, as well as other appropriate relief, including
attorney’s fees and litigation expenses, the costs of this action, pre and post judgment interest,
and any other legal, equitable, injunctive or declaratory relief that may be just and appropriate.
96. Plaintiffs, SHABRINA MCCLOUD and BONITA RAY, restate and incorporate by
97. This cause of action is brought against defendants, Tequila Crump and Ursula
their duties to care for and protect Ta’Naejah and instead neglected, physically abused and
99. As a direct and proximate result of the caretaker’s reckless, willful and wanton
100. Each of the caretakers exhibited a conscious disregard for the rights and safety
of Ta’Naejah despite a great probability that substantial harm and death would result from such
failure. Such reckless conduct gives rise to the imposition of punitive damages.
101. As a direct and proximate result of one or more of the aforesaid acts or
omissions, Ta’Naejah McCloud, sustained injuries resulting in her death on March 19, 2017
as administrator of the Estate of Ta’Naejah McCloud brings this wrongful death action,
103. That on or about March 19, 2017, Ta’Naejah McCloud left surviving her:
All the above have suffered pecuniary loss, including grief and sorrow and loss of society
WHEREFORE, Plaintiffs prays for judgment against each Defendant, jointly and
cause of action in this complaint, an amount significantly in excess of $25,000 as and for punitive
expenses, the costs of this action, pre and post judgment interest, and any other legal, equitable,
restates and incorporates by reference, Paragraphs 1 through 97 of this Complaint as fully re
written herein.
99. Prior to her death, Decedent Ta’Naejah McCloud endured great pain and
suffering as a direct and proximate result of Defendants' willful, wanton, negligent acts and
pursuant to the Ohio Survival Act, O.R.C 2305.21, this cause of action, by reason of such pain
McCloud, deceased, prays for judgment against each Defendants, jointly and severally, in an
complaint, as well as other appropriate relief, including attorney’s fees and litigation expenses,
the costs of this action, pre and post judgment interest, and any other legal, equitable, injunctive
Respectfully submitted,
-and-
Respectfully submitted,
-and-