Preview
FQ
CIVIL ACTION DOCKET NO.(S) Trial Court of Massachusetts
COVER SHEET Superior Court Department
County: BRISTOL
ADVIACNCOL A
PLAINTIFF(S) DEFENDANT(S)
Katherine Voshell, as Administrator of the Estate of Eric L. Voshell Marin}, LLC dfs 1C"s Ca & Restaurant and 20* Real Estate Management,
Inc, BRISTOL, SS SUPERIOR COURT
‘ATTORNEY, FIRM NAME, ADDRESS AND TELEPHONE. ATTORNEY (if known) FILED
Patrick T. Jones (253960), Robert A. DeLello (634475), and Erin K. Thurston
(689736) Jones Kelleher LLP, 21 Custom House St. Boston MA 02110
(TEL) 617-737-3100
AUG 94 2094
Origin code and track designation
Place an x in one box only: . 4 F04 District Court Apy Ae Sato S, ESQ.
X 1. FO! Original Complaint and 104 (After trial) (
+ 2. F02 Removal to Sup. Ct. C.231, s.104 . 5. iSrefig STRATE
F05 Reactivated after reseripe Teli
(Before trial) (F) from judgment/Order (M.R.C.P 60) (X)
. 3. F03 Retransfer to Sup..Ct. C.231, s. 102c (x) 6. E10 Summary Process Appeal (X),
TYPE OF ACTION AND TRACK DESIGNATION
CODE NO. TYPE OF ACTION (specify) TRACK IS THIS A JURY CASE?
BO4
B04 Other Negligence ~ Personal Injury
(F) (X) Yes ( )No
The following is a full, itemized and detailed statement of the facts on which plaintiff relies to determine money damages. For this form,
disregard double or treble damage claims; indicate single damages only.
TORT CLAIMS
(Attach additional sheets as necessary)
Documented medical expenses to date:
1 Total hospital expenses.
2. Total doctor expenses. $
3 Total chiropractic expenses. $
Total physical therapy expenses $
Total other expenses (describe’ 'UNERAL AND BURIAL. $5,000 +
Subtotal $5,000 +
Documented lost wages and compensation to date. $400,000+
Documented property damages to date. $
Reasonably anticipated future medical and hospital expense $
Reasonably anticipated lost wages. $500,00 +
Other documented items of damages (describe).
Brief description of plaintiff's injury, including nature and extent of injury (describe),
Please see attached addendum.
Total: $Jury Determination
CONTRACT CLAIMS
(Attach additional sheets as necessary)
Provide a detailed description of claim(s)
Total: $
PLEASE IDENTIFY, BY CASE NUMBER, NAME AND COUNTY, ANY RELATED ACTION PENDING IN THE
SUPERIOR COURT DEPT.
“] hereby certify that I have complied with the requirement of Rule 5 of the Supreme Judicial Court Uniform Rules on
Dispute Resolution (SJC Rule 1:18) required that I provide my clients with information about court-connected dispute
resolution services and discuss with them the advantages and disadvantages of the various methods.”
Signature of Attorney of Record /s/ Patrick T. Jones DATE: August 31, 2021
Katherine Voshell, as Administrator of the Estate of Eric L. Voshell v. Martinj, LLC d/b/a JC’s Café &
Re estaurant, and
stestaurant, and 20
20" Real
Keal Estate
Estate Management,
Management, Inc.
Inc.
Addendum to Civil Action Cover Sheet, Paragraph G
On or about September 13, 2019, Voshell suffered serious bodily injury, endured conscious pain and
suffering, and, on September 14, 2019, died as a result of the careless and negligent ownership, maintenance,
control and operation of the premises by the Defendants, their agents, servants, and/or employees. Eric L.
Voshell is survived by his wife, Katherine Voshell, their two minor children, and his adult son, Ian.
As a direct and proximate result of the Defendants’ wrongful conduct, Katherine and Voshell’s minor
children, have lost the society, comfort, services, care, companionship, support, and consortium of Voshell.
This is an action against the Defendants for their negligence, gross negligence and recklessness in failing to
maintain their premises in a reasonably safe manner, failing to provide and maintain adequate security, failing
to abide by their own rules and regulations and failing to take reasonable precautions and actions to protect their
patrons, all of which directly and. proximately caused the serious bodily injury, conscious pain and suffering,
and death of Eric L. Voshell.
Preview
FQ CIVIL ACTION DOCKET NO.(S) Trial Court of Massachusetts COVER SHEET Superior Court Department County: BRISTOL ADVIACNCOL A PLAINTIFF(S) DEFENDANT(S) Katherine Voshell, as Administrator of the Estate of Eric L. Voshell Marin}, LLC dfs 1C"s Ca & Restaurant and 20* Real Estate Management, Inc, BRISTOL, SS SUPERIOR COURT ‘ATTORNEY, FIRM NAME, ADDRESS AND TELEPHONE. ATTORNEY (if known) FILED Patrick T. Jones (253960), Robert A. DeLello (634475), and Erin K. Thurston (689736) Jones Kelleher LLP, 21 Custom House St. Boston MA 02110 (TEL) 617-737-3100 AUG 94 2094 Origin code and track designation Place an x in one box only: . 4 F04 District Court Apy Ae Sato S, ESQ. X 1. FO! Original Complaint and 104 (After trial) ( + 2. F02 Removal to Sup. Ct. C.231, s.104 . 5. iSrefig STRATE F05 Reactivated after reseripe Teli (Before trial) (F) from judgment/Order (M.R.C.P 60) (X) . 3. F03 Retransfer to Sup..Ct. C.231, s. 102c (x) 6. E10 Summary Process Appeal (X), TYPE OF ACTION AND TRACK DESIGNATION CODE NO. TYPE OF ACTION (specify) TRACK IS THIS A JURY CASE? BO4 B04 Other Negligence ~ Personal Injury (F) (X) Yes ( )No The following is a full, itemized and detailed statement of the facts on which plaintiff relies to determine money damages. For this form, disregard double or treble damage claims; indicate single damages only. TORT CLAIMS (Attach additional sheets as necessary) Documented medical expenses to date: 1 Total hospital expenses. 2. Total doctor expenses. $ 3 Total chiropractic expenses. $ Total physical therapy expenses $ Total other expenses (describe’ 'UNERAL AND BURIAL. $5,000 + Subtotal $5,000 + Documented lost wages and compensation to date. $400,000+ Documented property damages to date. $ Reasonably anticipated future medical and hospital expense $ Reasonably anticipated lost wages. $500,00 + Other documented items of damages (describe). Brief description of plaintiff's injury, including nature and extent of injury (describe), Please see attached addendum. Total: $Jury Determination CONTRACT CLAIMS (Attach additional sheets as necessary) Provide a detailed description of claim(s) Total: $ PLEASE IDENTIFY, BY CASE NUMBER, NAME AND COUNTY, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPT. “] hereby certify that I have complied with the requirement of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SJC Rule 1:18) required that I provide my clients with information about court-connected dispute resolution services and discuss with them the advantages and disadvantages of the various methods.” Signature of Attorney of Record /s/ Patrick T. Jones DATE: August 31, 2021 Katherine Voshell, as Administrator of the Estate of Eric L. Voshell v. Martinj, LLC d/b/a JC’s Café & Re estaurant, and stestaurant, and 20 20" Real Keal Estate Estate Management, Management, Inc. Inc. Addendum to Civil Action Cover Sheet, Paragraph G On or about September 13, 2019, Voshell suffered serious bodily injury, endured conscious pain and suffering, and, on September 14, 2019, died as a result of the careless and negligent ownership, maintenance, control and operation of the premises by the Defendants, their agents, servants, and/or employees. Eric L. Voshell is survived by his wife, Katherine Voshell, their two minor children, and his adult son, Ian. As a direct and proximate result of the Defendants’ wrongful conduct, Katherine and Voshell’s minor children, have lost the society, comfort, services, care, companionship, support, and consortium of Voshell. This is an action against the Defendants for their negligence, gross negligence and recklessness in failing to maintain their premises in a reasonably safe manner, failing to provide and maintain adequate security, failing to abide by their own rules and regulations and failing to take reasonable precautions and actions to protect their patrons, all of which directly and. proximately caused the serious bodily injury, conscious pain and suffering, and death of Eric L. Voshell.