DOCUMENT 2

ELECTRONICALLY FILED
6/3/2025 6:25 PM
52-CV-2025-900281.00
CIRCUIT COURT OF
MORGAN COUNTY, ALABAMA
CHRIS PRIEST, CLERK
IN THE CIRCUIT COURT OF MORGAN COUNTY, ALABAMA

JAMES CORY HASTINGS, as the natural and

custodial father of CHLOE ROSE HASTINGS, a
deceased minor;

PLAINTIFF, CIVIL ACTION NO.

v. CV-2025-

KEVIN JAY PENICH; DECATUR OPCO, LLC, dba

BUFFALO WILD WINGS; PATTON WINGS, INC., dba
BUFFALO WILD WINGS; WINGIN’ IT, LLC, dba
BUFFALO WILD WINGS; ALFONSO’S PIZZA, INC.;
LOGAN’S ROADHOUSE II, LLC; FICTITIOUS
PARTIES NO. 1-5, being that person, firm, corporation,
partnership, or other entity that negligently caused or failed
to prevent Chloe Rose Hastings’ death; FICTITIOUS
PARTIES NO. 6-10, being that person, firm, corporation,
partnership, or other entity that wantonly caused or failed to
prevent Chloe Rose Hastings’ death; FICTITIOUS PARTIES
NO. 11-15, being that employer, master or principal of that
person, firm, corporation, partnership, or other entity that
negligently and/or wantonly caused or failed to prevent Chloe
Rose Hastings’ death; FICTITIOUS PARTIES NO. 16-20,
being that person, firm, company, corporation, partnership,
mutual insurance company, or other entity that issued a
policy of motor vehicle insurance providing uninsured
motorist and/or underinsured motorist coverage for plaintiff’s
decedent, or its assignee or successor in interest all of whose
names are unknown to Plaintiffs but will be added by
amendment when ascertained; FICTITIOUS PARTIES NO.
21-25, being that person, firm, corporation, partnership, or
other entity that negligently and/or wantonly entrusted a
motor vehicle to defendant and/or any other person who
proximately caused or failed to prevent Chloe Rose Hastings’
death; all of whose names are unknown to Plaintiff but will
be added by amendment when ascertained; FICTITIOUS
PARTIES NO. 26-30, being such individuals, partnerships,
corporations or other entities whose identities are unknown
to the plaintiff but who or which may have furnished alcohol
to Kevin Jay Penich contrary to law, whose names are
unknown but will be added by amendment when ascertained;
FICTITIOUS PARTIES NO. 31-40, being such individuals,
partnerships, corporations or other entities whose identities
are unknown to the plaintiff but who or which negligently
and/or wantonly failed to train, supervise or hire bartenders,
 DOCUMENT 2

servers, or other similar staff responsible for the sale and

service of alcoholic beverages to Kevin Jay Penich contrary
to law , whose names are unknown but will be added by
amendment when ascertained;

DEFENDANTS.

COMPLAINT FOR WRONGFUL DEATH

COMES NOW the Plaintiff, by and through counsel, and claims of the Defendants as

follows:

1. James Cory Hastings is an individual over the age of nineteen (19) and is a resident of

Morgan County, Alabama. Plaintiff James Cory Hastings was the sole custodial parent of

Chloe Rose Hastings, a minor who died in a motor vehicle collision on or about May 17,

2025. Plaintiff James Cory Hastings brings this wrongful death action pursuant to Ala.

Code §§ 6-5-390, 6-5-391, and 6-5-410.

2. Defendant Kevin Jay Penich is believed by the plaintiffs to be over the age of nineteen (19)

and a resident of Morgan County, Alabama.

3. Defendant Decatur OpCo, LLC, dba Buffalo Wild Wings, is a corporation doing business

by agent in Morgan County, Alabama.

4. Defendant Patton Wings, Inc., dba Buffalo Wild Wings, is a corporation doing business by

agent in Morgan County, Alabama.

5. Defendant Wingin’ It, LLC, dba Buffalo Wild Wings, is a corporation doing business by

agent in Morgan County, Alabama.

6. Defendant Alfonso’s Pizza, Inc. is a corporation doing business by agent in Morgan

County, Alabama.
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7. Defendant Logan’s Roadhouse II, LLC is a corporation doing business by agent in Morgan

County, Alabama.

8. Fictitious Parties 1-5, being that person, firm, corporation, partnership, or other entity that

negligently caused or failed to prevent Chloe Rose Hastings’ death; all of whose names are

unknown to Plaintiff but will be added by amendment when ascertained.

9. Fictitious Parties 6-10, being that person, firm, corporation, partnership, or other entity that

wantonly caused or failed to prevent Chloe Rose Hastings’ death; all of whose names are

unknown to Plaintiff but will be added by amendment when ascertained.

10. Fictitious Parties 11-15, being that employer, master or principal of that person, firm,

corporation, partnership, or other entity that negligently and/or wantonly caused or failed

to prevent Chloe Rose Hastings’ death; all of whose names are unknown to Plaintiff but

will be added by amendment when ascertained.

11. Fictitious Parties 16-20, being that person, firm, company, corporation, partnership, mutual

insurance company, or other entity that issued a policy of motor vehicle insurance

providing uninsured motorist and/or underinsured motorist coverage for plaintiff’s

decedent, or its assignee or successor in interest all of whose names are unknown to

Plaintiff but will be added by amendment when ascertained.

12. Fictitious Parties 21-25, being that person, firm, corporation, partnership, or other entity

that negligently and/or wantonly entrusted a motor vehicle to defendant and/or any other

person who proximately caused or failed to prevent Chloe Rose Hastings’ death; all of

whose names are unknown to Plaintiff but will be added by amendment when ascertained.

13. Fictitious Parties 26-30, being such individuals, partnerships, corporations or other entities

whose identities are unknown to the Plaintiff but who or which may have furnished alcohol
 DOCUMENT 2

to Kevin Jay Penich contrary to law, whose names are unknown but will be added by

amendment when ascertained.

14. Fictitious Parties 31-40, being such individuals, partnerships, corporations or other entities

whose identities are unknown to the Plaintiff but who or which negligently and/or wantonly

failed to train, supervise or hire bartenders, servers, or other similar staff responsible for

the sale and service of alcoholic beverages to Kevin Jay Penich contrary to law, whose

names are unknown but will be added by amendment when ascertained.

15. The true names and identities of the other named defendants are unknown to Plaintiffs at

this time and will be added by amendment in accordance with Rule 9(h) of the Alabama

Rules of Civil Procedure when the true names and identities are ascertained.

16. On or about the 17th day of May, 2025, Defendant Kevin Jay Penich was operating his

vehicle at a high rate of speed, in excess of the posted speed limit, on the streets and

highways of the State of Alabama while intoxicated. Kevin Jay Penich, while traveling at

an excessive speed, struck the vehicle driven by Chloe Rose Hastings.

17. As a proximate result of being struck by Kevin Jay Penich’s vehicle, Chloe Rose Hastings

suffered severe bodily injuries resulting in her death.

18. In the hours prior to striking and killing Chloe Rose Hastings, Kevin Jay Penich had

consumed alcohol from Decatur OpCo, LLC, dba Buffalo Wild Wings, and/or Patton

Wings, Inc., dba Buffalo Wild Wings, and/or Wingin’ It, LLC, dba Buffalo Wild Wings.

Further, Kevin Jay Penich also consumed additional quantities of alcohol at Alfonso’s

Pizza, Inc. and Logan’s Roadhouse II, LLC.

19. Decatur OpCo, LLC, dba Buffalo Wild Wings, and/or Patton Wings, Inc., dba Buffalo

Wild Wings, and/or Wingin’ It, LLC, dba Buffalo Wild Wings, at all times relevant to the
 DOCUMENT 2

allegations of the complaint, are incorporated business entities with their principal place of

business located at 945 Wimberly Drive SW, Decatur, Morgan County, Alabama 35603.

Said corporations operate as a restaurant doing business as Buffalo Wild Wings that sells

food and beer and spirituous liquors. At all times material hereto, Decatur OpCo, LLC,

dba Buffalo Wild Wings, and/or Patton Wings, Inc., dba Buffalo Wild Wings, and/or

Wingin’ It, LLC, dba Buffalo Wild Wings, were doing business in Morgan County,

Alabama. Said entities sold, furnished or provided alcohol to Kevin Jay Penich, even

though he was intoxicated.

20. Alfonso’s Pizza, Inc., at all times relevant to the allegations of the complaint, is a business

entity incorporated under the laws of the State of Alabama with its principal place of

business located at 725 Beltline Road SW, Suite E, Decatur, Morgan County, Alabama

35603. Said corporation is a restaurant that sells food and beer and spirituous liquors. At

all times material hereto, Alfonso’s Pizza, Inc. was doing business in Morgan County,

Alabama. Said entity sold, furnished or provided alcohol to Kevin Jay Penich, even though

he was intoxicated.

21. Logan’s Roadhouse II, LLC, at all times relevant to the allegations of the complaint, is a

business entity incorporated under the laws of the State of Alabama with its principal place

of business located at 2315 Beltline Road SW, Decatur, Morgan County, Alabama 35603.

Said corporation is a restaurant that sells food and beer and spirituous liquors. At all times

material hereto, Logan’s Roadhouse II, LLC was doing business in Morgan County,

Alabama. Said entity sold, furnished or provided alcohol to Kevin Jay Penich, even though

he was intoxicated.

22. As a result of consuming the excessive alcohol sold, furnished, and provided by Decatur
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OpCo, LLC, dba Buffalo Wild Wings, and/or Patton Wings, Inc., dba Buffalo Wild Wings,

and/or Wingin’ It, LLC, dba Buffalo Wild Wings, and/or Alfonso’s Pizza, Inc. and/or

Logan’s Roadhouse II, LLC, Kevin Jay Penich became intoxicated, operated his vehicle

while intoxicated, and ultimately struck and killed Chloe Rose Hastings.

COUNT ONE
Defendants Decatur OpCo, LLC; Patton Wings, Inc.; Wingin’ It, LLC;
Alfonso’s Pizza, Inc.; Logan’s Roadhouse II, LLC

CIVIL DAMAGES ACT

DRAM SHOP CLAIM PURSUANT TO ALA. CODE§ 6-5-71 and/or ALABAMA
ALCOHOLIC BEVERAGE CONTROL BOARD RULES AND REGULATIONS,
SECTION 20-X-6.02

23. Plaintiff adopts and realleges the allegations in the foregoing paragraphs by reference as if

fully set out herein.

24. Ala. Code§ 6-5-71, "The Alabama Dram Shop Act" states:

the wife, child, parent, or other person who shall be injured in person, property
or means of support by any intoxicated person or in consequence of the intoxication
of any person shall have a right of action against any person, who shall, by
selling, giving, or otherwise disposing of to another, contrary to the provisions of
law, any liquors or beverages, cause the intoxication of such person for all
damages actually sustained as well as exemplary damages.

25. Alabama Alcoholic Beverage Control Board Rules and Regulations, Section

20-X-6-.02, states:

"No licensee or employee of a licensee shall serve or dispense alcoholic beverages to any

person visibly intoxicated.”

26. On or about May 17, 2025, the Defendants Decatur OpCo, LLC, dba Buffalo Wild

Wings, and/or Patton Wings, Inc., dba Buffalo Wild Wings, and/or Wingin’ It, LLC, dba

Buffalo Wild Wings, and/or Alfonso’s Pizza, Inc. and/or Logan’s Roadhouse II, LLC

including Fictitious Party Defendants 26-30, separately and severally, unlawfully sold or
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otherwise furnished alcoholic beverages or other intoxicating liquors or beverages to

Kevin Jay Penich. The Defendants' actions, separately and severally, were in violation of

the Alabama Civil Damages Act and The Dram Shop Act and the other laws of the State

of Alabama and regulations of The ABC Board.

27. Defendants Decatur OpCo, LLC, dba Buffalo Wild Wings, and/or Patton Wings, Inc., dba

Buffalo Wild Wings, and/or Wingin’ It, LLC dba Buffalo Wild Wings and/or Alfonso’s

Pizza, Inc. and/or Logan’s Roadhouse II, LLC, Fictitious Party Defendants 26-30,

separately and severally, knew or should have known, or could have ascertained through

the exercise of reasonable and proper care, that Kevin Jay Penich was intoxicated.

28. As a direct and proximate result of the Defendants', Fictitious Party Defendants 26-30,

separate and several, violation of the Civil Damages Claim Act, § 6-5-71, and/or The

Alabama Dram Shop Act and/or the Alabama Alcoholic Beverage Control Board Rules

and Regulations, Section 20-X-6-.02, Kevin Jay Penich became intoxicated, operated a

motor vehicle while intoxicated, and struck the vehicle driven by Chloe Rose Hastings

causing her death.

WHEREFORE Plaintiff, in all capacities, requests judgment against Decatur OpCo, LLC;

Patton Wings, Inc.; Wingin’ It, LLC; Alfonso’s Pizza, Inc. and Logan’s Roadhouse II, LLC and

Fictitious Party Defendants 26-30 separately and severally, for punitive damages, costs and such

other further relief a jury deems appropriate to punish the defendants and deter similar conduct

pursuant to the laws of the State of Alabama.

COUNT TWO
Negligent and/or Wanton Hiring, Training, or Supervision by
Defendants Decatur OpCo, LLC; Patton Wings, Inc.; Wingin’ It, LLC;
Alfonso’s Pizza, Inc.; Logan’s Roadhouse II, LLC

29. Plaintiff adopts and realleges the allegations in the foregoing paragraphs by reference as if
 DOCUMENT 2

fully set out herein.

30. Prior to the fatal collision of May 17, 2025, which claimed the life of Chloe Rose Hastings,

Defendants Decatur OpCo, LLC; Patton Wings, Inc.; Wingin’ It, LLC; Alfonso’s Pizza,

Inc.; Logan’s Roadhouse II, LLC; and/or Defendants Nos. 26–40, negligently and/or

wantonly hired, trained, and supervised bartenders, servers, and other staff responsible for

the sale and service of alcoholic beverages.

31. As a direct and foreseeable result of Defendants’ negligent and/or wanton hiring, training,

and supervision of these employees, Kevin Jay Penich was over-served and became

intoxicated. Thereafter, he unlawfully, negligently, and recklessly operated a motor

vehicle, colliding with the vehicle driven by Chloe Rose Hastings and causing her death.

32. Chloe Rose Hastings’ death was the direct consequence of Defendants’ failure to properly

hire, train, and supervise their employees entrusted with the sale and service of alcohol.

WHEREFORE, Plaintiff demands judgment against Defendants, jointly and severally, for

all available damages, including punitive damages, costs of court, and such further relief as

Plaintiff may be entitled in the premises.

COUNT THREE
Wrongful Death
Defendants Decatur OpCo, LLC; Patton Wings, Inc.; Wingin’ It, LLC;
Alfonso’s Pizza, Inc.; Logan’s Roadhouse II, LLC

33. Plaintiff adopts and realleges the allegations in the foregoing paragraphs by reference as if

fully set out herein.

34. On or about May 17, 2025, Defendants Decatur OpCo, LLC; Patton Wings, Inc.; Wingin’

It, LLC; Alfonso’s Pizza, Inc.; and Logan’s Roadhouse II, LLC and/or Fictitious Party
 DOCUMENT 2

Defendants 26-30 each owed a duty to exercise reasonable care in the service of alcoholic

beverages, and to comply with all applicable laws, rules, and regulations governing the sale

and service of alcohol, including but not limited to Ala. Code § 6-5-71 and Ala. Code § 28-

3A-25.

35. Defendants Decatur OpCo, LLC; Patton Wings, Inc.; Wingin’ It, LLC; Alfonso’s Pizza,

Inc.; and Logan’s Roadhouse II, LLC and/or Fictitious Party Defendants 26-30 breached

said duty when they negligently, wantonly, and/or recklessly caused and/or allowed

Defendant Kevin Jay Penich to become intoxicated and thereafter failed to take reasonable

steps to prevent further service or consumption of alcohol.

These negligent, wanton and/or reckless acts and omissions include, but are not limited to:

(1) Serving alcohol to Defendant Penich when he was visibly intoxicated in violation of

Alabama law;

(2) Failing to properly monitor Defendant Penich’s level of intoxication while continuing

to serve him alcoholic beverages;

(3) Failing to implement or enforce responsible alcohol service policies or procedures;

(4) Failing to properly train employees on the legal and safe service of alcohol, including

the duty to refuse service to an intoxicated person;

(5) Encouraging or permitting excessive consumption of alcohol by Defendant Penich for

purposes of increasing sales or tips;

(6) Continuing to serve alcohol to Defendant Penich despite clear signs of intoxication,

including slurred speech, unsteady gait, impaired motor function, and other obvious signs

of impairment;

(7) Failing to refuse further service of alcohol or to take reasonable steps to prevent
 DOCUMENT 2

Defendant Penich from operating a motor vehicle after becoming intoxicated.

36. As a direct and proximate consequence of Defendants Decatur OpCo, LLC; Patton Wings,

Inc.; Wingin’ It, LLC; Alfonso’s Pizza, Inc.; and Logan’s Roadhouse II, LLC and/or

Fictitious Party Defendants 26-30 wrongful, negligent, wanton, and/or reckless conduct,

Chloe Rose Hastings suffered severe bodily injuries from which she died.

WHEREFORE, Plaintiff James Cory Hastings, as Chloe Rose Hastings’ natural and

custodial father, demands judgment for all damages recoverable under Alabama’s Wrongful Death

Statute, to wit, Ala. Code § 6-5-410, and Ala. Code § 32-5A-191 including but not limited to

punitive damages for the death of Chloe Rose Hastings in an amount that will adequately reflect

the enormity of the Defendant’s wrongful acts and will effectively prevent other similar wrongful

acts.

COUNT FOUR
Negligence-Defendant Kevin Jay Penich

37. Plaintiff adopts and realleges the allegations in the foregoing paragraphs by reference as if

fully set out herein.

38. On or around May 17, 2025, upon a public road or highway, to-wit: the intersection of

Beltline Road and Westmead Street in Morgan County, Alabama, Defendant Kevin Jay

Penich and/or Defendants No. 1-10 negligently operated a motor vehicle, causing a

collision and the resulting death of Chloe Rose Hastings.

39. As a direct and proximate result of Defendant’s negligence, a collision occurred.

Subsequently, Chloe Rose Hastings’ vehicle caught fire while she remained inside,

resulting in her suffering fatal injuries.

WHEREFORE, Plaintiff claims of the Defendant punitive damages, costs and such other

further relief as Plaintiff may be entitled in the premises.

 DOCUMENT 2

COUNT FIVE
Wanton Misconduct-Defendant Kevin Jay Penich

40. Plaintiff adopts and realleges the allegations in the foregoing paragraphs by reference as if

fully set out herein.

41. On or around May 17, 2025, upon a public road or highway, to-wit: the intersection of

Beltline Road and Westmead Street in Morgan County, Alabama, Defendant Kevin Jay

Penich and/or Defendants No. 1-10, wantonly operated a motor vehicle, causing a collision

and the resulting death of Chloe Rose Hastings.

42. As a direct and proximate result of Defendant’s wanton misconduct, a collision occurred.

Subsequently, Chloe Rose Hastings’ vehicle caught fire while she remained inside,

resulting in her suffering fatal injuries.

WHEREFORE, Plaintiff claims of the Defendant punitive damages, costs and such other

further relief as Plaintiff may be entitled in the premises.

COUNT SIX
Wrongful Death-Defendant Kevin Jay Penich

43. Plaintiff adopts and realleges the allegations in the foregoing paragraphs by reference as if

fully set out herein.

44. On or about May 17, 2025, Defendant Kevin Jay Penich had a duty to use reasonable care

to avoid causing harm to others while using the public roadways.

45. Defendant committed negligence per se by violating the Alabama Rules of the Road, to

wit: Section 32-5A-191 Code of Alabama, Driving Under the Influence.

46. As a direct and proximate consequence of Defendant’s negligence per se, Chloe Rose

Hastings suffered severe bodily injuries from which she died.

WHEREFORE, Plaintiff James Cory Hastings, as Chloe Rose Hastings’ natural and
 DOCUMENT 2

custodial father, demands judgment for all damages recoverable under Alabama’s Wrongful Death

Statute, to wit, Ala. Code § 6-5-410, and Ala. Code § 32-5A-191 including but not necessarily

limited to punitive damages for the death of Chloe Rose Hastings in an amount that will adequately

reflect the enormity of the Defendant’s wrongful acts and will effectively prevent other similar

wrongful acts.

COUNT SEVEN
Combined and Concurring Negligence
Defendants Kevin Jay Penich; Decatur OpCo, LLC; Patton Wings, Inc.;
Wingin’ It, LLC; Alfonso’s Pizza, Inc.; Logan’s Roadhouse II, LLC

47. Plaintiff adopts and realleges the allegations in the foregoing paragraphs by reference as if

fully set out herein.

48. On or about May 17, 2025, Defendants acted negligently, wantonly, and in violation of

Alabama law, and as a proximate result of their combined and concurring conduct, caused

the wrongful death of Chloe Rose Hastings.

WHEREFORE, Plaintiff, in all capacities, requests judgment against Kevin Jay Penich;

Decatur OpCo, LLC; Patton Wings, Inc.; Wingin’ It, LLC; Alfonso’s Pizza, Inc.; Logan’s

Roadhouse II, LLC; and Fictitious Party Defendants 1-40 separately and severally, for the

wrongful death of his daughter, Chloe Rose Hastings, punitive damages, costs and such other

further relief a jury deems appropriate to punish the defendants and deter similar conduct pursuant

to the laws of the State of Alabama.

COUNT EIGHT
Negligent Entrustment-Fictitious Party Defendants No. 21-25

49. Plaintiff adopts and realleges the allegations in the foregoing paragraphs by reference as if

fully set out herein.

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50. On or about May 17, 2025, Defendants No. 21-25, whose true names are unknown to

Plaintiff but will be added by amendment when ascertained negligently entrusted a vehicle

to Defendant Kevin Jay Penich, who by reason of his lack of skill or judgment or condition

was not qualified to operate said vehicle in a reasonably safe manner, all of which

Defendants No. 21-25 knew or should have known. As a proximate cause of the negligent

entrustment by Defendants No. 21-25 of a vehicle to Defendant Kevin Jay Penich,

Defendant Kevin Jay Penich so negligently and/or wantonly operated said vehicle so as to

cause it to strike the vehicle driven by Chloe Rose Hastings, resulting in her fatal injuries.

WHEREFORE, Plaintiff claims of the Defendants punitive damages, costs and such other

further relief as Plaintiff may be entitled in the premises.

GENERAL AVERMENTS

51. Plaintiff adopts and realleges the allegations in the foregoing paragraphs as if fully set out

herein.

52. In addition to the specific allegations set forth above, Plaintiff avers that the negligence

and/or wanton conduct of all Defendants combined and concurred to cause the wrongful

death of Chloe Rose Hastings.

53. Plaintiff avers that fictitious parties 1-15 negligently and/or wantonly caused or failed to

prevent Chloe Rose Hastings’ death. The true names and identities of each fictitiously

described Defendant is unknown to the Plaintiff at this time and will be added by

amendment in accordance with Rule 9(h) of the Alabama Rules of Civil Procedure when

the true names are ascertained.

54. Plaintiff avers that fictitious parties 16-20 issued a policy or policies of automobile

insurance that provided uninsured/underinsured motorist coverage to Plaintiff and that said
 DOCUMENT 2

policy or policies were in full force and effect at the time of said automobile accident and

provided coverage for the death of Chloe Rose Hastings. The true names and identities of

each fictitiously described Defendant is unknown to the Plaintiff at this time and will be

added by amendment in accordance with Rule 9(h) of the Alabama Rules of Civil

Procedure when the true names are ascertained.

55. Plaintiff avers that fictitious parties 21-25 negligently and/or wantonly entrusted a motor

vehicle to Defendant Kevin Jay Penich and/or any other person who proximately caused

or failed to prevent the wrongful death of Chloe Rose Hastings. The true names and

identities of each fictitiously described Defendant is unknown to the Plaintiff at this time

and will be added by amendment in accordance with Rule 9(h) of the Alabama Rules of

Civil Procedure when the true names are ascertained.

56. Plaintiff avers that fictitious parties 26-30, being such individuals, partnerships,

corporations or other entities whose identities are unknown to the Plaintiff but who or

which may have furnished alcohol to Kevin Jay Penich contrary to law, whose names are

unknown but will be added by amendment when ascertained.

57. Plaintiff avers that fictitious parties 31-40, being such individuals, partnerships,

corporations or other entities whose identities are unknown to the Plaintiff but who or

which negligently and/or wantonly failed to train, supervise or hire bartenders, servers, or

other similar staff responsible for the sale and service of alcoholic beverages to Kevin Jay

Penich contrary to law, whose names are unknown but will be added by amendment when

ascertained.
 DOCUMENT 2

GARNETT PATTERSON INJURY LAWYERS, LLC

/s/ Hunter S. Garnett

Hunter S. Garnett (GAR127)
100 Jefferson Street, Suite 300
Huntsville AL 35801
(256) 539-8686
(256) 289-2114- Fax
[email protected]
Attorneys for Plaintiff

/s/ Robert E. Patterson

Robert E. Patterson (PAT015)
100 Jefferson Street, Suite 300
Huntsville AL 35801
(256) 539-8686
(256) 289-2114- Fax
[email protected]
Attorneys for Plaintiff

PLAINTIFF HEREBY DEMANDS TRIAL BY STRUCK JURY

/s/ Hunter S. Garnett

Hunter S. Garnett (GAR127)

SERVE DEFENDANTS AT:

Kevin Jay Penich

Morgan County Jail

Decatur OpCo, LLC

dba Buffalo Wild Wings
c/o CT Corp System
2 North Jackson St., Ste. 605
Montgomery, AL 36104

Patton Wings, Inc.

dba Buffalo Wild Wings
c/o Matthew Soderman
13405 W Star Dr.
Shelby Township, MI 48315
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Wingin’ It, LLC

dba Buffalo Wild Wings
c/o National Registered Agents, Inc.
2 N Jackson St., Ste. 605
Montgomery, AL 36104

Alfonso’s Pizza, Inc.

c/o Marie Barbee, Reg. Agent
2400 6th Ave SE
Decatur, AL 35601

Logan’s Roadhouse II, LLC

c/o CT Corporation System
2 North Jackson St., Ste. 605
Montgomery, AL 36104