Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 1 of 36
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`Date Filed _________________________
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`Case Number _________________________
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`Defendant(s)
`Plaintiff(s)
`Ninebot Inc.
`Turner, Zella
`__________________________________________________ __________________________________________________
`Last
`First
`Middle I.
`Suffix
`Prefix Last First Middle I.
`Suffix
`Prefix
`Segway, Inc.
`__________________________________________________ __________________________________________________
`Last First Middle I.
`Suffix
`Prefix Last First Middle I.
`Suffix
`Prefix
`Social Bicycles, LLC, d/b/a Jump Bikes
`__________________________________________________ __________________________________________________
`Last First Middle I.
`Suffix
`Prefix Last First Middle I.
`Suffix
`Prefix
`Uber Technogies, Inc.
`__________________________________________________ __________________________________________________
`Last First Middle I.
`Suffix
`Prefix Last First Middle I.
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`M. Alan Holcomb
`879771
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`State Court of Fulton County
`***EFILED***
`File & ServeXpress
`Transaction ID: 64469852
`Date: Nov 27 2019 11:12AM
`LeNora Ponzo, Chief Clerk
`Civil Division
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 2 of 36
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`IN THE STATE COURT OF FULTON COUNTY
`STATE OF GEORGIA
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`ZELLA TURNER,
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`Plaintiff,
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`vs.
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`NINEBOT INC., SEGWAY INC.,
`SOCIAL BICYCLES, LLC d/b/a
`JUMP BIKES,
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`UBER TECHNOLOGIES, INC.,
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`JOHN DOES 1 through 5, and JOHN
`DOE CORPORATIONS 1 through 5,
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`Defendants.
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`CIVIL ACTION FILE NO.
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`________________
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`JURY TRIAL DEMANDED
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`COMPLAINT FOR DAMAGES
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`Plaintiff ZELLA TURNER (“Plaintiff”), by and through her undersigned counsel, hereby
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`files this Complaint for Damages against Defendants NINEBOT INC., SEGWAY INC.,
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`SOCIAL BICYCLES, LLC d/b/a JUMP BIKES, UBER TECHNOLOGIES, INC., JOHN
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`DOES 1 through 5, and JOHN DOE CORPORATIONS 1 through 5, alleging as follows:
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`PARTIES
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`1.
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`Plaintiff ZELLA TURNER (“Plaintiff” or “Ms. Turner”) is a resident of, a citizen
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`of, and domiciled in Georgia. By filing this Complaint, Ms. Turner is availing herself of the
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`jurisdiction and venue of this Court.
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`2.
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`Defendant NINEBOT INC. (“Ninebot”) is a for-profit Delaware corporation, with
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`its headquarters located in Beijing, China, and its principal place of business in the United States
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`located in New Hampshire. Ninebot’s registered agent for service of process is Business Filings
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`Incorporated (USE 9325335), 108 West 13th Street, Wilmington, Delaware. Defendant Ninebot is
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`subject to the jurisdiction of this Court pursuant to O.C.G.A. § 9-10-91 because it regularly solicits
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`business in Georgia and sells its products directly to Georgia consumers; Ninebot sells its products
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`State Court of Fulton County
`***EFILED***
`File & ServeXpress
`Transaction ID: 64469852
`Date: Nov 27 2019 11:12AM
`LeNora Ponzo, Chief Clerk
`Civil Division
`
`
`
`

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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 3 of 36
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`to distributors in Georgia with the expectation and knowledge that they will be purchased by
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`Georgia consumers; Ninebot committed a tortuous act which caused damages in Georgia; and
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`Ninebot derives substantial revenue from products used in Georgia. Venue is proper in this Court
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`as to this Defendant.
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`3.
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`Defendant SEGWAY, INC. (“Segway”) is a for-profit Delaware corporation doing
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`business in Georgia with its principal place of business in New Hampshire. The registered agent
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`for service of process on Segway is CT Corporation System, located at 2 1/2 Beacon Street,
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`Concord, New Hampshire 03301-4447. Defendant Segway is subject to the jurisdiction of this
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`Court pursuant to O.C.G.A. § 9-10-91 because it regularly solicits business in Georgia and sells
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`its products directly to Georgia consumers; Segway sells its products to distributors in Georgia
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`with the expectation and knowledge that they will be purchased by Georgia consumers; Segway
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`committed a tortuous act which caused damages in Georgia; and Segway derives substantial
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`revenue from products used in Georgia. Venue is proper in this Court as to this Defendant.
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`4.
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`Defendant SOCIAL BICYCLES, LLC d/b/a JUMP BIKES (“Social Bicycles”)
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`is a for-profit New York limited liability company doing business in Georgia with its principal
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`place of business in New York. Social Bicycles’ registered agent for service of process is CT
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`Corporation System, located at 289 South Culver Street, Lawrenceville, Georgia 30046, Gwinnett
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`County. Defendant Social Bicycles is subject to the jurisdiction and venue of this Court.
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`5.
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`Defendant UBER TECHNOLOGIES, INC. (“Uber Technologies”) is a for-profit
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`Georgia corporation with its principal place of business located in Georgia. Uber Technologies’
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`registered agent for service of process is Gregory Scott Smith, 7550 Hunters Woods Drive,
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`Dunwoody, Georgia 30350, Fulton County. Defendant Uber Technologies is subject to the
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`jurisdiction and venue of this Court.
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 4 of 36
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`6.
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`Defendants JOHN DOES 1 through 5 and JOHN DOE CORPORATIONS 1
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`through 5 (collectively, “John Doe Defendants”) are believed to be individuals, for-profit
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`Georgia or foreign corporations, partnerships, associations, other legal entities, and/or persons that
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`have transacted business in Georgia and are responsible for the injuries and damages incurred by
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`Ms. Turner. Once the identity and the whereabouts of the John Doe Defendants are established,
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`said Defendants will be served with a copy of Summons and Complaint as provided by law. The
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`John Doe Defendants are subject to the jurisdiction and venue of this Court.
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`BACKGROUND FACTS
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`7.
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`On or about January 19, 2019, Plaintiff sustained severe, life-threatening, and
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`permanent injuries as the result of her use of a Ninebot/Segway electric scooter in Atlanta, Georgia.
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`8.
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`These injuries were the result of the unlawful acts and omissions of Ninebot and
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`Segway for their negligent design, manufacture, marketing, and distribution of fleets of defective
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`electric scooters, and all Defendants’ failure to adequately maintain, inspect, and/or repair said
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`scooters. All Defendants failed to adequately warn about the dangers of the use of Ninebot/Segway
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`scooters.
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`9.
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`These “pay as you go” electric scooters were designed, manufactured, and sold by
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`Ninebot and Segway and deployed by Uber and Social Bicycles onto the public streets, sidewalks
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`and other public places within the city of Atlanta and other cities in Georgia. Uber and Social
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`Bicycles and their related entities do this by deploying dockless scooters throughout a city that
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`may be rented at any time while a scooter is deployed.
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`10.
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`The scooters Uber and/or Social Bicycles uses are designed, manufactured, and
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`produced by Ninebot and/or Segway.
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 5 of 36
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`11.
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`Defendants Uber and Social Bicycles owned the electric scooter and leased it to
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`Plaintiff. Employees of Defendants Uber and Social Bicycles were responsible for marketing,
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`maintaining, testing, inspecting, and repairing the electric scooter, as well as adequately warning
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`about dangers associated with its use. Employees of these Defendants selected the electric scooter
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`for public use, and negligently trained and supervised Plaintiff in its use.
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`12.
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`Uber and Social Bicycles are one of the largest users of Ninebot and Segway
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`products in the world.
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`13.
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`Since Uber’s and Social Bicycles’ deployment of electronic scooters, there have
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`been numerous reports of injuries suffered as a result of equipment failures. See, e.g., Peter Holley,
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`Lime scooter riders are being injured by ‘sudden excessive braking,’ company says,
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`WASHINGTON
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`POST
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`(Feb.
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`25,
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`2019),
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`https://www.washingtonpost.com/technology/2019/02/25/lime-scooter- riders-are-being-injured-
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`by-sudden-excessive-braking-company-admits/; Arman Azad, That electric scooter might be fun.
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`It also might be deadly, CNN, Oct. 1, 2018, https://www.cnn.com/2018/09/29/health/scooter-
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`injuries/index.html; Ryan Felton, E- Scooter Ride-Share Industry Leaves Injuries and Angered
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`Cities
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`in
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`its
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`Path,
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`CONSUMER
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`REPORTS,
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`Feb.
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`5,
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`2019,
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`https://www.consumerreports.org/product-safety/e-scooter-ride-share-industry-leaves-injuries-
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`and-angered-cities-in-its-path/; Andrew J. Hawkins, Electric scooter use results in 20 injuries per
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`100,000
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`trips,
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`CDC
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`find,
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`THE
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`VERGE,
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`May
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`2,
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`2019,
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`https://www.theverge.com/2019/5/2/18526813/scooter-electric-injury-austin-cdc-study-head-
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`helmet.
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`4
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 6 of 36
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`14.
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`Plaintiff’s injuries were directly and proximately caused by Defendants’ collective
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`failure to warn of dangers in the product, Defendants’ failure to inspect, maintain, and repair the
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`electric scooter, as well as defects in the design and/or manufacture of the scooter.
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`15.
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`The defects include, without limitation: the sticking of the accelerator on the
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`scooter; the sudden, unexpected, and rapid acceleration of the scooter; an unstable center of
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`gravity; the fact that the scooter was deceivingly powerful; the small wheels, which made it
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`unstable; and the dangerous operation of the brakes, which may have caused the scooter to throw
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`Plaintiff forward and onto a pavement/fence when she attempted to stop the scooter.
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`16.
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`Plaintiff was a user in the class of persons that each Defendant should reasonably
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`foresee as being subject to the harm caused by the defective conditions of the scooter.
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`COUNT ONE – NEGLIGENCE
`(Defendants Ninebot and Segway)
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`Plaintiff hereby incorporates all preceding allegations in this Complaint as if
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`17.
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`expressly set forth herein.
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`18.
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`At all relevant times, Defendants Ninebot and Segway were engaged in the business
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`of designing, manufacturing, assembling, marketing, and/or selling (directly or through
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`distributors) devices such as the electric scooter which are intended to be used as modes of
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`transportation for consumers like Plaintiff.
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`19.
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`Defendants Ninebot and Segway were specifically responsible for the design,
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`manufacture, and assembly of the electric scooter.
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`20.
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`Defendants Ninebot and Segway were responsible for putting the electric scooter
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`into the stream of commerce where it eventually reached members of the consuming public,
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`specifically Ms. Turner, so they could ride electric scooters through the streets of Atlanta.
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`21.
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`As the designer, manufacturer, marketer, and seller of the electric scooter,
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`5
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 7 of 36
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`Defendants Ninebot and Segway owed a duty of care to Ms. Turner and the consuming public in
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`general to design safe equipment free from defects.
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`22.
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`Defendants Ninebot and Segway also had a duty to adequately warn owners and
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`users of the electric scooter, as well as the consuming public, about dangers of which they were or
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`should have been aware of on the electric scooter.
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`23.
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`Defendants Ninebot and Segway specifically marketed this product as both durable
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`and safe for its intended uses. The electric scooter was intended to be used by consumers like
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`Plaintiff under a variety of weather and other road conditions without suffering a catastrophic
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`failure.
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`24.
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`Defendants Ninebot and Segway were negligent and were the factual cause of the
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`injuries, harm, damages, and losses of Plaintiff in that these Defendants:
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`a) Failed to design, fabricate, manufacture, assemble, market, and/or sell a safe and
`non-defective electric scooter;
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`b) Failed to adequately and carefully test the electric scooter;
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`c) Failed to select the proper component parts for the electric scooter;
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`d) Failed to carefully select and employ appropriate materials, suitable to safely
`transport a member of the consuming public;
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`e) Failed to employ proper design and manufacture techniques in order to ensure a safe
`final product;
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`f) Failed to carefully test and/or inspect this particular electric scooter before it was
`sold, leased, and/or delivered to Uber/Social Bicycles;
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`g) Failed to provide a product that was safe and durable for its intended use;
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`h) Negligently represented and marketed the electric scooter as being safe and durable
`for its intended use, and as being of appropriate quality for its use in the streets of
`Atlanta under a variety of conditions; and,
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`i) Failed to warn users and consumers of the defects in said electric scooter.
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 8 of 36
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`25.
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`The tortious conduct of Defendants Ninebot and Segway was not only negligent,
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`but it exhibited a willful, reckless, and/or wanton disregard for life and property because
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`Defendants knew that there was a considerable risk of severe injury and/or death in the event that
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`its electric scooter failed in the manner in which it did here. Defendants were required to take
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`special care and precautions that the electric scooter was safe for its intended uses, where special,
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`unusual, and/or dangerous conditions could exist.
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`26.
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`Defendants Ninebot and Segway had an affirmative duty to warn its customers and
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`the consuming public who it could reasonably foresee would use its product about potential
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`failures in the electric scooter that could - and would likely - result in serious injury or death.
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`Defendants failed to do any of these things and breached their duties to Ms. Turner and its other
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`customers in these and other respects.
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`27.
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`For this and other reasons, these Defendants are liable to Ms. Turner for all damages
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`allowable by Georgia law, including punitive damages.
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`COUNT TWO – STRICT LIABILITY
`(Defendants Ninebot and Segway)
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`28.
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`Plaintiff hereby incorporates all preceding allegations in this Complaint as if
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`expressly set forth herein.
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`29.
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`Defendants Ninebot and Segway were engaged in the business of designing,
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`manufacturing, assembling, marketing, and/or selling (directly or through distributors) devices
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`such as the electric scooter which are intended to be used as modes of transportation for consumers
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`like Plaintiff.
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`30.
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`The defective condition of the electric scooter rendered such product unreasonably
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`dangerous. This product was in this defective condition at the time it left the hands of Defendants,
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`and such product was a producing cause of Plaintiff’s injuries and damages.
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 9 of 36
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`31.
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`This electric scooter, without substantial change in the condition in which it was
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`sold, was a proximate and/or producing cause of Plaintiff’s injuries and damages.
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`32.
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`Plaintiff was unaware of the hazards and defects in Defendant Ninebot’s and
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`Segway’s electric scooter that made it unsafe for its intended purpose.
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`33.
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`The electric scooter was being used in a manner that was intended by Defendants
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`Ninebot and Segway and/or, in the alternative, used in a foreseeable manner.
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`34.
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`The conduct of Defendants Ninebot and Segway as described above was committed
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`with a conscious disregard for the safety of Plaintiff and others, and Plaintiff is entitled to seek and
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`obtain punitive damages against Defendants Ninebot and Segway by reason of such conduct.
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`35.
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`For this and other reasons, these Defendants are liable to Ms. Turner under a theory
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`of strict liability for all damages allowable by Georgia law, including punitive damages.
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`COUNT THREE –NEGLIGENCE
`(Defendants Uber and Social Bicycles)
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`36.
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`Plaintiff hereby incorporates all preceding allegations in this Complaint as if
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`expressly set forth herein.
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`37.
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`Defendants Uber and Social Bicycles supplied the scooter in an unreasonably
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`dangerous condition. The dangers posed by the scooter were a non-obvious danger to
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`inexperienced riders such as Ms. Turner.
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`38.
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`These Defendants knew or had reason to know that the electric scooter was likely
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`to be dangerous to an end product consumer when used in the reasonably expected manner that
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`Ms. Turner utilized.
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`39.
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`Such dangers were, in part, the result of Defendants Uber’s and Social Bicycles’
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`negligent failure to test, inspect, maintain, and repair the electric scooter, as well as their negligent
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`failure to warn about dangers associated with the electric scooter.
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 10 of 36
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`40.
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`The conduct of Defendants Uber and Social Bicycles as described above was
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`committed with a conscious disregard for the safety of Plaintiff and others, and Plaintiff is entitled
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`to seek and obtain punitive damages against these Defendants by reason of such conduct.
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`41.
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`For this and other reasons, these Defendants are liable to Ms. Turner for all damages
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`allowable by Georgia law, including punitive damages.
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`COUNT FOUR – GROSS NEGLIGENCE
`(All Defendants)
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`42.
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`Plaintiff hereby incorporates all preceding allegations in this Complaint as if
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`expressly set forth herein.
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`43.
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`The negligent acts and omissions of all Defendants as described above constituted
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`an absence of even the slightest degree of diligence, or lack of any care, or care for the safety of
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`Plaintiff and the consuming public. Defendants’ acts and omissions constituted an extreme
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`departure from what a reasonably careful person would have dome in the same situation to prevent
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`harm to Ms. Turner and/or the general public. All Defendants acted with a reckless disregard for
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`the safety of Plaintiff and the consuming public.
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`44.
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`For this and other reasons, these Defendants are liable to Ms. Turner for all damages
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`allowable by the law, including punitive damages.
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`COUNT FIVE – PUNITIVE DAMAGES
`(All Defendants)
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`45.
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`Plaintiff hereby incorporates all preceding allegations in this Complaint as if
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`expressly set forth herein.
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`46.
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`Defendants, through their conduct in designing, manufacturing, selling, warning
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`about, and/or leasing the electric scooter demonstrated gross neglect and an entire want of care
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`evidencing a reckless indifference and conscious disregard to the consequences of its actions,
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 11 of 36
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`which included an extreme degree of risk. Plaintiff is entitled to an award of punitive damages to
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`deter Defendants from such conduct in the future.
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`47.
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`Despite Defendants’ knowledge of the dangerous defects in electric scooters,
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`Defendants did nothing to remedy or mitigate the problem so that innocent victims like Ms. Turner
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`would not be injured, maimed, or killed.
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`48.
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`As a result of Defendants’ callous, wanton, reckless, and conscious indifference to
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`the safety and well-being of the consumer public and users of the electric scooters, numerous
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`victims have been injured in similar incidents over time, and people continue to be injured.
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`49.
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`There is clear and convincing evidence that Defendants acted with such willful,
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`wanton, conscious, and reckless indifference, which demonstrated an entire wanton of care for the
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`safety and well-being of victims like those involved in the Incident and others so as to evidence a
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`conscious indifference to the consequences of its acts, which included an extreme degree of risk.
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`These actions demand and warrant an award of punitive damages against Defendants that will
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`punish them for the harm they have caused and that will deter it from similar future misconduct.
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`COUNT SIX – ATTORNEY’S FEES AND EXPENSES OF LITIGATION
`(All Defendants)
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`Defendants have been stubbornly litigious and have caused Plaintiff unnecessary
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`50.
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`expense so as to entitle Plaintiff to the expenses of litigation and attorney’s fees as defined by
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`O.C.G.A. § 13-6-11. Defendants have acted in bad faith and have forced Plaintiff to file this
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`lawsuit in order to receive compensation for her injuries.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff prays for a judgment to be awarded to her and against
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`Defendants for the following:
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`a) All legally compensable damages in excess of $75,000.00 that were inflicted by
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 12 of 36
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`Defendants, which she suffered in the past and she will continue to suffer in the
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`future, including, but not limited to, compensation for physical pain, emotional
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`distress, mental anguish, disfigurement, physical impairment, lost wages, lost earning
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`capacity, pecuniary loss, loss of companionship and society, medical expenses,
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`property damage, and any additional damages, including attorneys’ fees;
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`b) Punitive damages in an amount sufficient to punish them for the harm caused by their
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`dangerous acts and omissions and to deter it from similar future misconduct;
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`c) Pre-judgment and post-judgment interest as allowed by applicable law;
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`d) Costs of this suit; and,
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`e) For such other and further relief as the Court deems just and proper.
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`DEMAND FOR JURY TRIAL
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`Plaintiff hereby demands a trial by 12 jurors on all issues so triable.
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`Submitted this 27th day of November, 2019.
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`3379 Peachtree Road, NE
`Suite 740
`Atlanta, GA 30326
`Tel: 404-793-2566
`Email: aholcomb@turnbullfirm.com
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`bturnbull@turnbullfirm.com
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`TURNBULL, CAIN & HOLCOMB, LLC
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`/s/ M. Alan Holcomb
`M. Alan Holcomb
`Georgia Bar No. 879771
`D. Brett Turnbull
`Georgia Bar No. 421898
`Attorneys for Plaintiff
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 13 of 36
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`THE MANCE LAW FIRM, LLC
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`/s/Chadrick A. Mance
`Chadrick A. Mance
`Georgia Bar No. 703877
`Attorney for Plaintiff
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`24 Commerce Place, Suite C
`Savannah, GA 31406
`Tel: 912-574-4529
`Email: mancelawgroup@gmail.com
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`12
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`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 14 of 36
`GEORGIA, FULTON COUNTY
`DO NOT WRITE IN THIS SPACE
`
`STATE COURT OF FULTON COUNTY
`Civil Division
`
`CIVIL ACTION FILE #: ___________________________
`
`TYPE OF SUIT
`
`AMOUNT OF SUIT
`
`_____________________________________
`_____________________________________
`_____________________________________
`Plaintiff’s Name, Address, City, State, Zip Code
`
` vs.
`
`_____________________________________
`_____________________________________
`_____________________________________
`Defendant’s Name, Address, City, State, Zip Code
`
`[ ] ACCOUNT
`[ ] CONTRACT
`[ ] NOTE
`[ ] TORT
`[ ] PERSONAL INJURY
`[ ] FOREIGN JUDGMENT
`[ ] TROVER
`[ ] SPECIAL LIEN
`
`PRINCIPAL $_____________
`
`INTEREST $______________
`
`ATTY. FEES $_____________
`
`COURT COST $ ___________
`
`************
`
`[ ] NEW FILING
`[ ] RE-FILING: PREVIOUS CASE NO. ___________________
`
`SUMMONS
`TO THE ABOVE NAMED-DEFENDANT:
`You are hereby required to file with the Clerk of said court and to serve a copy on the Plaintiff’s Attorney, or on Plaintiff if no Attorney, to-wit:
`Name: ______________________________________________
`Address: ____________________________________________
`City, State, Zip Code: __________________________________________________ Phone No.:___________________________
`An answer to this complaint, which is herewith served upon you, must be filed within thirty (30) days after service, not counting the day of service. If you
`fail to do so, judgment by default will be taken against you for the relief demanded in the complaint, plus cost of this action.DEFENSES MAY BE MADE &
`JURY TRIAL DEMANDED, via electronic filing or, if desired, at the e-filing public access terminal in the Self-Help Center at 185 Central Ave., S.W.,
`Ground Floor, Room TG300, Atlanta, GA 30303.
`
`LeNora Ponzo, Chief Clerk (electronic signature)
`
`______________________________________________________________________________________________________________________
`
`SERVICE INFORMATION:
`Served, this _______ day of ____________________, 20______.
`
`_______________________________________________
`DEPUTY MARSHAL, STATE COURT OF FULTON COUNTY
`
`WRITE VERDICT HERE:
`We, the jury, find for ______________________________________________________________________________________________
`_______________________________________________________________________________________________________________
`This _________ day of _______________________, 20_____. ______________________________________ Foreperson
`
`(STAPLE TO FRONT OF COMPLAINT)
`
`Zella Turner
`
`19EV006505
`
`811 McGill Park Avenue
`
`Atlanta, GA 30312
`
`x
`
`x
`
`x
`
`Ninebot Inc. c/o Business Filings Incorporated
`(USE 9325335)
`
`108 West 13th Street
`
`Wilmington, Delaware 19081
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`M. Alan Holcomb
`
`3379 Peachtree Road, NE, Suite 740
`
`Atlanta, GA 30326 404-793-2566
`
`- Turnbull, Cain & Holcomb, LLC
`
`State Court of Fulton County
`***EFILED***
`File & ServeXpress
`Transaction ID: 64470889
`Case Number: 19EV006505
`Date: Nov 27 2019 12:00PM
`LeNora Ponzo, Chief Clerk
`Civil Division
`
`
`
`
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`

`

`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 15 of 36
`GEORGIA, FULTON COUNTY
`DO NOT WRITE IN THIS SPACE
`
`STATE COURT OF FULTON COUNTY
`Civil Division
`
`CIVIL ACTION FILE #: ___________________________
`
`TYPE OF SUIT
`
`AMOUNT OF SUIT
`
`_____________________________________
`_____________________________________
`_____________________________________
`Plaintiff’s Name, Address, City, State, Zip Code
`
` vs.
`
`_____________________________________
`_____________________________________
`_____________________________________
`Defendant’s Name, Address, City, State, Zip Code
`
`[ ] ACCOUNT
`[ ] CONTRACT
`[ ] NOTE
`[ ] TORT
`[ ] PERSONAL INJURY
`[ ] FOREIGN JUDGMENT
`[ ] TROVER
`[ ] SPECIAL LIEN
`
`PRINCIPAL $_____________
`
`INTEREST $______________
`
`ATTY. FEES $_____________
`
`COURT COST $ ___________
`
`************
`
`[ ] NEW FILING
`[ ] RE-FILING: PREVIOUS CASE NO. ___________________
`
`SUMMONS
`TO THE ABOVE NAMED-DEFENDANT:
`You are hereby required to file with the Clerk of said court and to serve a copy on the Plaintiff’s Attorney, or on Plaintiff if no Attorney, to-wit:
`Name: ______________________________________________
`Address: ____________________________________________
`City, State, Zip Code: __________________________________________________ Phone No.:___________________________
`An answer to this complaint, which is herewith served upon you, must be filed within thirty (30) days after service, not counting the day of service. If you
`fail to do so, judgment by default will be taken against you for the relief demanded in the complaint, plus cost of this action.DEFENSES MAY BE MADE &
`JURY TRIAL DEMANDED, via electronic filing or, if desired, at the e-filing public access terminal in the Self-Help Center at 185 Central Ave., S.W.,
`Ground Floor, Room TG300, Atlanta, GA 30303.
`
`LeNora Ponzo, Chief Clerk (electronic signature)
`
`______________________________________________________________________________________________________________________
`
`SERVICE INFORMATION:
`Served, this _______ day of ____________________, 20______.
`
`_______________________________________________
`DEPUTY MARSHAL, STATE COURT OF FULTON COUNTY
`
`WRITE VERDICT HERE:
`We, the jury, find for ______________________________________________________________________________________________
`_______________________________________________________________________________________________________________
`This _________ day of _______________________, 20_____. ______________________________________ Foreperson
`
`(STAPLE TO FRONT OF COMPLAINT)
`
`19EV006505
`
`Zella Turner
`
`811 McGill Park Avenue, NE
`
`Atlanta, GA 30312
`
`Segway, Inc
`c/o CT Corporation
`
`2 1/2 Beacon Street
`
`Concord, NH 03301-4447
`
`M. Alan Holcomb
`
`3379 Peachtree Road, NE, Suite 740
`
`Atlanta, GA 30326 404-793-2566
`
`x
`
`x
`
`x
`
` - Turnbull, Cain & Holcomb, LLC
`
`State Court of Fulton County
`***EFILED***
`File & ServeXpress
`Transaction ID: 64470889
`Case Number: 19EV006505
`Date: Nov 27 2019 12:00PM
`LeNora Ponzo, Chief Clerk
`Civil Division
`
`
`
`
`
`

`

`Case 1:20-cv-00002-LMM Document 1-1 Filed 01/02/20 Page 16 of 36
`GEORGIA, FULTON COUNTY
`DO NOT WRITE IN THIS SPACE
`
`STATE COURT OF FULTON COUNTY
`Civil Division
`
`CIVIL ACTION FILE #: ___________________________
`
`TYPE OF SUIT
`
`AMOUNT OF SUIT
`
`_____________________________________
`_____________________________________
`_____________________________________
`Plaintiff’s Name, Address, City, State, Zip Code
`
` vs.
`
`_____________________________________
`_____________________________________
`_____________________________________
`Defendant’s Name, Address, City, State, Zip Code
`
`[ ] ACCOUNT
`[ ] CONTRACT
`[ ] NOTE
`[ ] TORT
`[ ] PERSONAL INJURY
`[ ] FOREIGN JUDGMENT
`[ ] TROVER
`[ ] SPECIAL LIEN
`
`PRINCIPAL $_____________
`
`INTEREST $______________
`
`ATTY. FEES $_____________
`
`COURT COST $ ___________
`
`************
`
`[ ] NEW FILING
`[ ] RE-FILING: PREVIOUS CASE NO. ___________________
`
`SUMMONS
`TO THE ABOVE NAMED-DEFENDANT:
`You are hereby required to file with the Clerk of said court and to serve a copy on the Plaintiff’s Attorney, or on Plaintiff if no Attorney, to-wit:
`Name: ______________________________________________
`Address: ____________________________________________
`City, State, Zip Code: __________________________________________________ Phone No.:___________________________
`An answer to this complaint, which is herewith served upon you, must be filed within thirty (30) days after service, not counting the day of service. If you
`fail to do so, judgment by default will be taken against you for the relief demanded in the complaint, plus cost of this action.DEFENSES MAY BE MADE &
`JURY TRIAL DEMANDED, via electronic filing or, if desired, at the e-filing public access terminal in the