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
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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 Courts 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 Courts 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
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and within this Courts 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
CETCOs and/or Enterprises 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.
Broussards fault and negligence.
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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 petitioners 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 petitioners 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. Broussards
vision.
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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. Operating his vehicle in disregard for petitioners safety;
B. Operating his vehicle in a careless manner;
C. Failing to keep a proper lookout for traffic in front of him;
D. Failing to timely see that petitioners vehicle was stopped at the Yield Sign;
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E. Failing to see what he should have seen and do what he should have done under the
circumstances;
F. Violating the provisions of La. R.S. 32:58;
G. Failing to obey the laws and regulations pertinent to traffic for Lafayette Parish and
the State of Louisiana.
23.
Petitioners injuries and damages were caused by the defendants legal fault, negligence,
careless, and omission of dutyas they are vicariously liable for the fault and negligence of their
employee, agent, or servant, Stanford D. Broussardand 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. Physical pain, suffering, and disfigurement;
B. Mental anguish and distress;
C. Loss or diminishment of the enjoyment of life;
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D. Medical and hospital costs;
E. 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 petitioners
damages.
27.
Ace American Insurance Companys policy contains no provisions or exclusions that are
applicable to this rear-end motor-vehicle collision and, as such, it is liable to pay petitioners
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.
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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
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""'JS 44 (Rev. 11104)
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.)
IV. NATURE oF SUIT (Place an "X" in One Box Only)
I. (a) PLAINTIFFS
LINDA F. BRUNO
(b) County of Residence of First Listed Plaintiff Louisiana

(EXCEPT IN U.S. PLAINTIFF CASES)
(c) Attorney's (Finn Name, Address, and Telephone Number)
Richard R. Kennedy, P.O. Box 3243, Lafayette, LA 70502
(337) 232-1934
DEFENDANTS
CETCO Oilfield Services Co" Enterprise FM Trust, and Ace
American Ins, Co.
County of Residence of First Listed Defendant Delaware & Pennsylvania
(IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE
LAND INVOL VED.
Attorneys (If Known)
Unknown
II. BASIS OF JURISDICTION (Place an "X" in One Box Only)
01 U.S. Government
Plaintiff
o 2 U.S. Government
Defendant
o 3 Federal Question
(U.S. Government Not a Party)
II 4 Diversity
(Indicate Citizenship of Parties in Item Ill)
III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an "X" in One Box for Plaintiff
(For Diversity Cases Only)
PTF
and One Box for Defendant)
DEF PTF DEF
Citizen of This State I o I Incorporated or Principal Place 0 4 0 4
of Business In This State
Citizen of Another State
Citizen or Subject of a
Forei Couo
o 2 .. 2 Incorporated and Principal Place o 5 ill 5
of Business In Another State
o 3 0 3 Foreign Nation o 6 0 6
ONTRACT TORTS FORFEITUREIPENALTY BANKRUPTCY OTHER STATUTES
o 110 Insurance
o 120 Marine
o 130 Miller Act
o 140 Negotiable Instrument
o 150 Recovery of Overpayment
& Enforcement of Judgment
o 151 Medicare Act
o 152 Recovery of Defaulted
Student Loans
(Exc!. Veterans)
o 153 Recovery of Overpayment
of Veteran's Benefits
o 160 Stockholders' Suits
o 190 Other Contract
o 195 Contract Product Liability
o 196 Franchise
PERSONAL INJURY PERSONAL INJURY
0 310 Airplane 0 362 Personal Injury
0 315 Airplane Product Med. Malpractice
Liability 0 365 Personal Injury -
0 320 Assault, Libel & Product Liability
Slander 0 368 Asbestos Personal
0 330 Federal Employers' Injury Product
Liability Liability
0 340 Marine PERSONAL PROPERTY
0 345 Marine Product 0 370 Other Fraud
Liability 0 371 Truth in Lending
III 350 Motor Vehicle 0 380 Other Personal
0 355 Motor Vehicle Property Damage
Product Liability 0 385 Property Damage
0 360 Other Personal Product Liability
Injury
0 610 Agriculture
0 620 Other Food & Drug
0 625 Drug Related Seizure
of Property 21 USC 88 I
0 630 Liquor Laws
0 640 R.R. & Truck
0 650 Airline Regs.
0 660 Occupational
Safety/Health
0 690 Other
o 422 Appeal 28 USC 158
o 423 Withdrawal
28 USC 157
0
0
0
0
0
0
0
0
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
PROPER' YRI HrS
o 820 Copyrights
o 830 Patent
o 840 Trademark
,ADOR SOCIA ,SE JRl 'Y
0 710 Fair Labor Standards
Act
0 720 LaborlMgmt. Relations
0 730 LaborlMgmt. Reporting
& Disclosure Act
0 740 Railway Labor Act
0 790 Other Labor Litigation
0 791 Empl. Ret. Inc.
Security Act
o 861 HIA (I 395fl)
o 862 Black Lung (923)
0863 DIWCIDIWW (405(g))
o 864 ssm Title XVI
o 865 RSI (405(g))
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS FEDERAL TAX SUITS
o 210 Land Condemnation
o 220 Foreclosure
o 230 Rent Lease & Ejectment
o 240 Torts to Land
o 245 Tort Product Liability
o 290 All Other Real Property
0 441 Voting
0 442 Employment
0 443 Housing!
Accommodations
0 444 Welfare
0 445 Arner. wlDisabilities-
Employment
0 446 Arner. wlDisabilities-
Other
0 440 Other Civil Rights
0 510 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
o 870 Taxes (U.S. Plaintiff
or Defendant)
o 871 IRS-Third Party
26 USC 7609
Appeal to District
V. ORIGIN (Place an "X" in One Box Only)
o 4 0 5 Transferred from 0 6
Judge from
o 7
I Original o 2 Removed from 0 3 Remanded from Reinstated or another district Multidistrict Magistrate
Proceedin State Court A ellate Court Reo ened s ecif Liti ation Jud ment
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.
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT:
UNDER F.R.C.P. 23 500,000.00 JURY DEMAND: 0 Yes ill No
VIII. RELATED CASE(S)
(See insttuctions):
IFANY DOCKET NUMBER
DATE
06/07/2011
FOR OFFICE USE ONLY
RECEIPT # AMOUNT JUDGE MAG. JUDGE
-------- --------- --------------
Case 6:11-cv-00837-RFD-PJH Document 1-1 Filed 06/07/11 Page 1 of 2 PageID #: 9
JS 44 Reverse (Rev. 11104)
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 1-1 Filed 06/07/11 Page 2 of 2 PageID #: 10
AO 440 (Rev. 12/09) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
Plaintiff
v. Civil Action No.
Defendant
SUMMONS IN A CIVIL ACTION
To: (Defendants name and address)
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 plaintiffs attorney,
whose name and address are:
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 Filed 06/07/11 Page 1 of 2 PageID #: 11
Western District of Louisiana
LINDA F. BRUNO
CETCO Oilfield Services Company, et al
CETCO Oil Field Services Company
C T Corporation Stystem
5615 Corporate Blvd., Suite 400B
Baton Rouge, LA 70808
Richard R. Kennedy, Esq.
Richard R. Kennedy (APLC)
309 Polk Street
P.O. Box 3243
Lafayette, LA 70502-3243
AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
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) ; or
I left the summons at the individuals 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 individuals last known address; or
I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
I returned the summons unexecuted because ; or
Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Servers signature
Printed name and title
Servers address
Additional information regarding attempted service, etc:
Case 6:11-cv-00837-RFD-PJH Document 1-2 Filed 06/07/11 Page 2 of 2 PageID #: 12
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AO 440 (Rev. 12/09) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
Plaintiff
v. Civil Action No.
Defendant
SUMMONS IN A CIVIL ACTION
To: (Defendants name and address)
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 plaintiffs attorney,
whose name and address are:
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 Filed 06/07/11 Page 1 of 2 PageID #: 13
Western District of Louisiana
LINDA F. BRUNO
CETCO Oilfield Services Company, et al
Enterprise FM Trust
C T Corporation Stystem
5615 Corporate Blvd., Suite 400B
Baton Rouge, LA 70808
Richard R. Kennedy, Esq.
Richard R. Kennedy (APLC)
309 Polk Street
P.O. Box 3243
Lafayette, LA 70502-3243
AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
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) ; or
I left the summons at the individuals 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 individuals last known address; or
I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
I returned the summons unexecuted because ; or
Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Servers signature
Printed name and title
Servers address
Additional information regarding attempted service, etc:
Case 6:11-cv-00837-RFD-PJH Document 1-3 Filed 06/07/11 Page 2 of 2 PageID #: 14
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AO 440 (Rev. 12/09) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
Plaintiff
v. Civil Action No.
Defendant
SUMMONS IN A CIVIL ACTION
To: (Defendants name and address)
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 plaintiffs attorney,
whose name and address are:
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 Filed 06/07/11 Page 1 of 2 PageID #: 15
Western District of Louisiana
LINDA F. BRUNO
CETCO Oilfield Services Company, et al
Ace Amercian Insurance Company
Louisiana Secretary of State
8585 Archives Avenue
Baton Rouge, LA 70809
Richard R. Kennedy, Esq.
Richard R. Kennedy (APLC)
309 Polk Street
P.O. Box 3243
Lafayette, LA 70502-3243
AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
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) ; or
I left the summons at the individuals 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 individuals last known address; or
I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
I returned the summons unexecuted because ; or
Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Servers signature
Printed name and title
Servers address
Additional information regarding attempted service, etc:
Case 6:11-cv-00837-RFD-PJH Document 1-4 Filed 06/07/11 Page 2 of 2 PageID #: 16
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