throbber
Case 2:20-cv-03244-WJM-MF Document 1 Filed 03/25/20 Page 1 of 168 PageID: 1
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`
`
`Marissa Vahlsing
`Marco Simons (pro hac vice pending)
`Rick Herz (pro hac vice pending)
`EarthRights International
`1612 K Street NW, Suite 800
`Washington, D.C. 20006
`Tel: 202-466-5188
`Fax: 202-466-5189
`
`
`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`Cause No. 20-3244
`
`COMPLAINT AND DEMAND FOR JURY
`TRIAL
`
`
`Jane Doe 8, et al.,
`
`
`Plaintiffs,
`
`v.
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`
`
`
`Chiquita Brands International, Inc., a New Jersey
`Corporation,
`
` Defendant.
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`On information and belief, Plaintiffs, by their attorneys, allege as follows:
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`ADDRESSES
`
`1.
`
`All Plaintiffs can be contacted through their counsel, EarthRights International, 1612 K
`
`Street NW #800, Washington, DC 20006. The street and postal addresses of the individual Plaintiffs
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`cannot be made public due to the substantial risk of violent reprisals against them. The street and
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`postal address of Defendant Chiquita Brands International, Inc. (CBI), is 1855 Griffin Road,
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`DCOTA Bldg, Suite C-436, Fort Lauderdale, FL 33004; their local office in New Jersey is 820 Bear
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`Tavern Road, Trenton, NJ 08628.
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`
`
`1
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`

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`
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`I.
`
`INTRODUCTION
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`2.
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`This case arises as a result of the actions of Defendant Chiquita Brands International, Inc.,
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`and its subsidiaries and affiliates (collectively, “Chiquita”), in funding, arming, and otherwise
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`supporting terrorist organizations in Colombia in their campaign of terror against the civilian
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`population of the Urabá region, in order to maintain its profitable control of Colombia’s banana
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`growing regions. Plaintiffs are family members of trade unionists, banana workers, political
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`organizers, social activists, and others targeted and killed by terrorists, most notably paramilitary
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`organizations including the United Self-Defense Groups of Colombia (Autodefensas Unidas de
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`Colombia, or AUC), from at least 1992 through 2004. In order to produce bananas in an environment
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`free from labor opposition and social disturbances, Chiquita funded, armed, and otherwise
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`supported these paramilitary groups. The deaths of Plaintiffs’ relatives were a direct, foreseeable, and
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`intended result of Chiquita’s illegal and tortious support of terrorist organizations. Chiquita’s actions
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`violated not only Colombian law and U.S. law, but also customary international law prohibiting
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`crimes against humanity, extrajudicial killing, torture, war crimes, and other abuses.
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`3.
`
`The Court has jurisdiction over this case with respect to claims based upon laws of the State
`
`II.
`
`JURISDICTION
`
`of New Jersey, any other applicable state, and/or the laws of Colombia.
`
`III.
`
`PARTIES
`
`4.
`
`The term “Plaintiffs” herein includes the named plaintiffs and the decedents on behalf of
`
`whom they bring this action.
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`5.
`
`Plaintiffs Jane Doe 213, Jane Doe 8, John Doe 211, John Doe 212, John Doe 213, John Doe
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`214, John Doe 215, Jane Doe 214, and Jane Doe 215 are residents and citizens of Colombia. They
`
`bring claims based on the death of their family member, John Doe 12, as well as their own injuries.
`
`
`
`2
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`

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`6.
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`Plaintiffs Jane Doe 9, Jane Doe 217, Jane Doe 218, Jane Doe 219, and Jane Doe 220 are
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`residents and citizens of Colombia. They bring claims based on the death of their family member,
`
`John Doe 13, as well as their own injuries. Jane Doe 217, Jane Doe 218, Jane Doe 219, and Jane
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`Doe 220 additionally bring claims based on the death of their mother, Jane Doe 216.
`
`7.
`
`Plaintiff Jane Doe 10 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her sons, John Doe 14 and John Doe 15, as well as her own injuries.
`
`8.
`
`Plaintiff Jane Doe 11 is a resident and citizen of Colombia. She brings claims based on the
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`death of her sister, Jane Doe 12, as well as her own injuries.
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`9.
`
`Plaintiff Jane Doe 13 is a resident and citizen of Colombia. She brings claims based on the
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`death of her partner, John Doe 16, as well as her own injuries.
`
`10.
`
`Plaintiff Jane Doe 14 is a resident and citizen of Colombia. She brings claims based on the
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`death of her partner, John Doe 17, as well as her own injuries.
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`11.
`
`Plaintiff Jane Doe 16 is a resident and citizen of Colombia. She brings claims based on the
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`death of her partner, John Doe 19, as well as her own injuries.
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`12.
`
`Plaintiff Jane Doe 17 is a resident and citizen of Colombia. She brings claims based on the
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`death of her son, John Doe 20, as well as her own injuries.
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`13.
`
`Plaintiff Jane Doe 18 is a resident and citizen of Colombia. She brings claims based on the
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`death of her husband, John Doe 21, as well as her own injuries.
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`14.
`
`Plaintiff Jane Doe 19 is a resident and citizen of Colombia. She brings claims based on the
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`death of her son, John Doe 22, as well as her own injuries.
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`15.
`
`Plaintiff Jane Doe 221 is a resident and citizen of Colombia. She brings claims based on the
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`death of her son, John Doe 24, as well as her own injuries.
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`16.
`
`Plaintiff Jane Doe 20 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 25, as well as her own injuries.
`
`
`
`3
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`

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`
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`17.
`
`Plaintiff Jane Doe 21 is a resident and citizen of Colombia. She brings claims based on the
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`deaths of her mother, Jane Doe 22, and her stepfather, John Doe 26, as well as her own injuries.
`
`18.
`
`Plaintiff Jane Doe 23 is a resident and citizen of Colombia. She brings claims based on the
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`death of her son, John Doe 27, and her husband, John Doe 28, as well as her own injuries.
`
`19.
`
`Plaintiff Jane Doe 24 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 29, as well as her own injuries.
`
`20.
`
`Plaintiff Jane Doe 25 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 30, as well as her own injuries.
`
`21.
`
`Plaintiff Jane Doe 26 is a resident and citizen of Colombia. She brings claims based on her
`
`own injuries.
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`22.
`
`Plaintiff Jane Doe 27 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her father, John Doe 105, as well as her own injuries.
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`23.
`
`Plaintiff Jane Doe 30 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her mother, Jane Doe 31, as well as her own injuries.
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`24.
`
`Plaintiff Jane Doe 99 is a resident and citizen of Colombia. She brings claims based on the
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`death of her mother, Jane Doe 100, as well as her own injuries.
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`25.
`
`Plaintiff Jane Doe 121 is a resident and citizen of Colombia. She brings claims based on her
`
`own injuries.
`
`26.
`
`Plaintiff Jane Doe 122 is a resident and citizen of Colombia. She brings claims based on her
`
`own injuries.
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`27.
`
`Plaintiff John Doe 23 is a resident and citizen of Colombia. He brings claims based on his
`
`own injuries.
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`28.
`
`Plaintiff John Doe 32 is a resident and citizen of Colombia. He brings claims based on his
`
`own injuries.
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`
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`4
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`

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`29.
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`Plaintiff John Doe 33 is a resident and citizen of Colombia. He brings claims based on his
`
`own injuries.
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`30.
`
`Plaintiff Jane Doe 28 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 34, and her partner, John Doe 150, as well as her own injuries.
`
`31.
`
`Plaintiff John Doe 35 is a resident and citizen of Colombia. He brings claims based on his
`
`own injuries.
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`32.
`
`Plaintiff John Doe 37 is a resident and citizen of Colombia. He brings claims based on his
`
`own injuries.
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`33.
`
`Plaintiff John Doe 39 is a resident and citizen of Colombia. He brings claims based on his
`
`own injuries.
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`34.
`
`Plaintiff John Doe 40 is a resident and citizen of Colombia. He brings claims based on his
`
`own injuries.
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`35.
`
`Plaintiff Jane Doe 32 is a resident and citizen of Colombia. She brings claims based on her
`
`own injuries.
`
`36.
`
`Plaintiffs Jane Doe 33, Jane Doe 34, John Doe 48, John Doe 49, and John Doe 50 are
`
`residents and citizens of Colombia. They bring claims based on the death of their family member,
`
`John Doe 47, as well as their own injuries.
`
`37.
`
`Plaintiff Jane Doe 35 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 51, as well as her own injuries.
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`38.
`
`Plaintiff Jane Doe 36, Jane Doe 224, Jane Doe 225, Jane Doe 226, and John Doe 216 are
`
`residents and citizens of Colombia. They bring claims based on the death of their family member,
`
`John Doe 52, as well as their own injuries.
`
`
`
`5
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`

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`39.
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`Plaintiffs Jane Doe 37, Jane Doe 38, Jane Doe 39, and John Doe 54 are residents and
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`citizens of Colombia. They bring claims based on the death of their family member, John Doe 53, as
`
`well as their own injuries.
`
`40.
`
`Plaintiffs Jane Doe 40, Jane Doe 41, Jane Doe 42, Jane Doe 43, Jane Doe 44, Jane Doe 227,
`
`John Doe 56, and John Doe 57, are residents and citizens of Colombia. They bring claims based on
`
`the death of their family member, John Doe 55, as well as their own injuries. Jane Doe 40, Jane Doe
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`42, Jane Doe 43, Jane Doe 44, John Doe 57, and Jane Doe 227 also bring claims based on the death
`
`of their family member, John Doe 217. Jane Doe 40, Jane Doe 42, Jane Doe 43, John Doe 57, and
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`Jane Doe 227 also bring claims arising from the death of their family member, John Doe 218.
`
`41.
`
`Plaintiffs Jane Doe 45 and John Doe 60 are residents and citizens of Colombia. They bring
`
`claims based on the death of their family member, John Doe 59, as well as their own injuries.
`
`42.
`
`Plaintiffs Jane Doe 46, Jane Doe 47, John Doe 62, and John Doe 63 are residents and
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`citizens of Colombia. They bring claims based on the death of their family member, John Doe 61, as
`
`well as their own injuries.
`
`43.
`
`Plaintiffs Jane Doe 48, John Doe 65, and Jane Doe 228 are residents and citizens of
`
`Colombia. They bring claims based on the death of their family member, John Doe 64, as well as
`
`their own injuries.
`
`44.
`
`Plaintiffs John Doe 66, Jane Doe 50, Jane Doe 51, Jane Doe 52, Jane Doe 53, and Jane Doe
`
`54 are residents and citizens of Colombia. They bring claims based on the death of their family
`
`member, John Doe 67, as well as their own injuries. Jane Doe 49 is deceased and is represented in
`
`this action by her daughter Jane Doe 52.
`
`45.
`
`Plaintiff Jane Doe 55 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 68, as well as her own injuries.
`
`
`
`6
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`46.
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`Plaintiffs Jane Doe 56, Jane Doe 57, Jane Doe 58, John Doe 70, and John Doe 219 are
`
`residents and citizens of Colombia. They bring claims based on the death of their family member,
`
`John Doe 69, as well as their own injuries.
`
`47.
`
`Plaintiffs Jane Doe 59, John Doe 71, and Jane Doe 60 are residents and citizens of
`
`Colombia. They bring claims based on the death of their family member, John Doe 72, as well as
`
`their own injuries.
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`48.
`
`Plaintiffs Jane Doe 61, John Doe 73, and John Doe 75 are residents and citizens of
`
`Colombia. They bring claims based on the death of their family member, John Doe 76, as well as
`
`their own injuries.
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`49.
`
`Plaintiffs Jane Doe 62, Jane Doe 63, Jane Doe 64, and John Doe 74 are residents and
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`citizens of Colombia. They bring claims based on the death of their family member, John Doe 78, as
`
`well as their own injuries.
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`50.
`
`Plaintiffs Jane Doe 65, Jane Doe 66, and Jane Doe 67 are residents and citizens of Colombia.
`
`They bring claims based on the death of their family member, John Doe 79, as well as their own
`
`injuries.
`
`51.
`
`Plaintiffs Jane Doe 68 and Jane Doe 69 are residents and citizens of Colombia. They bring
`
`claims based on the death of their mother, Jane Doe 70, as well as their own injuries.
`
`52.
`
`Plaintiffs Jane Doe 75, Jane Doe 76, Jane Doe 77, and Jane Doe 78 are residents and citizens
`
`of Colombia. They bring claims based on the deaths of their family members, John Doe 82 and
`
`John Doe 220, as well as their own injuries.
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`53.
`
`Plaintiffs Jane Doe 79, Jane Doe 81, Jane Doe 82, Jane Doe 83, Jane Doe 84, Jane Doe 85,
`
`and John Doe 222 are residents and citizens of Colombia. They bring claims based on the death of
`
`their family members, John Doe 83 and John Doe 221, as well as their own injuries.
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`7
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`54.
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`Plaintiffs Jane Doe 86, John Doe 84, Jane Doe 87, and Jane Doe 88 are residents and
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`citizens of Colombia. They bring claims based on the death of their family member, John Doe 85, as
`
`well as their own injuries.
`
`55.
`
`Plaintiffs Jane Doe 90, John Doe 88, Jane Doe 91, John Doe 89, John Doe 90, and Jane Doe
`
`92 are residents and citizens of Colombia. They bring claims based on the death of their family
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`members, John Doe 91 and John Doe 223, as well as their own injuries. John Doe 88 is deceased
`
`and is represented in this action by Jane Doe 91.
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`56.
`
`Plaintiff Jane Doe 93 is a resident and citizen of Colombia. She brings claims based on the
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`death of her father, John Doe 92, as well as her own injuries.
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`57.
`
`Plaintiffs Jane Doe 94, Jane Doe 95, and John Doe 93 are residents and citizens of
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`Colombia. They bring claims based on the death of their mother, Jane Doe 96, as well as their own
`
`injuries.
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`58.
`
`Plaintiffs John Doe 94 and Jane Doe 97 are residents and citizens of Colombia. They bring
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`claims based on the death of their father, John Doe 95, as well as their own injuries.
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`59.
`
`Plaintiffs Jane Doe 98, John Doe 96, and John Doe 97 are residents and citizens of
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`Colombia. They bring claims based on the death of their family member, John Doe 98, as well as
`
`their own injuries. John Doe 96 is deceased and is represented in this action by Jane Doe 98.
`
`60.
`
`Plaintiffs Jane Doe 103, Jane Doe 104, and John Doe 102 are residents and citizens of
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`Colombia. They bring claims based on the death of their family member, John Doe 103, as well as
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`their own injuries.
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`61.
`
`Plaintiffs Jane Doe 105 and Jane Doe 106 are residents and citizens of Colombia. They bring
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`claims based on the death of their family member, John Doe 104, as well as their own injuries.
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`8
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`62.
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`Plaintiffs Jane Doe 109, Jane Doe 110, Jane Doe 111, Jane Doe 112, and John Doe 108 are
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`residents and citizens of Colombia. They bring claims based on the death of their family member,
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`John Doe 109, as well as their own injuries.
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`63.
`
`Plaintiffs Jane Doe 113, John Doe 110, John Doe 111, Jane Doe 114, Jane Doe 115, Jane
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`Doe 116, John Doe 112, Jane Doe 117, and Jane Doe 118 are residents and citizens of Colombia.
`
`They bring claims based on the death of their family member, John Doe 113, as well as their own
`
`injuries.
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`64.
`
`Plaintiff John Doe 114 is a resident and citizen of Colombia. He brings claims based on the
`
`death of his brother, John Doe 115, as well as his own injuries.
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`65.
`
`Plaintiffs Jane Doe 119, Jane Doe 120, Jane Doe 123, Jane Doe 124, Jane Doe 141, Jane
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`Doe 142, John Doe 116, John Doe 117, John Doe 118, and John Doe 119 are residents and citizens
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`of Colombia. They bring claims based on the death of their family member, John Doe 120, as well
`
`as their own injuries.
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`66.
`
`Plaintiffs Jane Doe 230, John Doe 224, John Doe 225, and Jane Doe 125 are residents and
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`citizens of Colombia. They bring claims based on the death of their family member, Jane Doe 229,
`
`as well as their own injuries. Jane Doe 125 also brings claims based on the death of her partner, John
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`Doe 121.
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`67.
`
`Plaintiffs Jane Doe 126, Jane Doe 127, Jane Doe 128, Jane Doe 129, Jane Doe 130, Jane
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`Doe 131, Jane Doe 132, Jane Doe 133, Jane Doe 134, Jane Doe 135, John Doe 123, John Doe 124,
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`John Doe 228, John Doe 226, John Doe 227, and John Doe 229 are residents and citizens of
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`Colombia. They bring claims based on the death of their family member, John Doe 125, as well as
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`their own injuries. Jane Doe 231 is deceased and is represented in this action by her daughter, Jane
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`Doe 232. Jane Doe 128 and John Doe 229 are deceased and are represented in this action by their
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`children, Jane Doe 130, Jane Doe 131, and John Doe 123.
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`9
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`68.
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`Plaintiffs Jane Doe 136, Jane Doe 137, Jane Doe 138, John Doe 126, John Doe 127, John
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`Doe 128, John Doe 129 and John Doe 130 are residents and citizens of Colombia. They bring
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`claims based on the death of their family member, John Doe 131, as well as their own injuries.
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`69.
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`Plaintiffs Jane Doe 139, Jane Doe 140 and John Doe 132 are residents and citizens of
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`Colombia. They bring claims based on the death of their family member, John Doe 133, as well as
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`their own injuries.
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`70.
`
`Plaintiffs Jane Doe 143, Jane Doe 144, John Doe 134, John Doe 135, and John Doe 136 are
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`residents and citizens of Colombia. They bring claims based on the death of their family member,
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`John Doe 137, as well as their own injuries.
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`71.
`
`Plaintiffs Jane Doe 101, Jane Doe 102, John Doe 99, John Doe 100, John Doe 101, and Jane
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`Doe 223 are residents and citizens of Colombia. They bring claims based on the death of their
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`family member, John Doe 38, as well as their own injuries.
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`72.
`
`Plaintiffs Jane Doe 145, Jane Doe 146, John Doe 139, Jane Doe 233, Jane Doe 234, Jane
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`Doe 235, and John Doe 230 are residents and citizens of Colombia. They bring claims based on the
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`death of their family member, John Doe 138, as well as their own injuries. John Doe 139 is deceased
`
`and is represented in this action by Jane Doe 233, Jane Doe 234, Jane Doe 235, and John Doe 230.
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`73.
`
`Plaintiff Jane Doe 147 is a resident and citizen of Colombia. She brings claims based on the
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`death of her partner, John Doe 140, as well as her own injuries.
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`74.
`
`Plaintiff Jane Doe 148 is a resident and citizen of Colombia. She brings claims based on the
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`death of her husband, John Doe 141, as well as her own injuries.
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`75.
`
`Plaintiff Jane Doe 149 is a resident and citizen of Colombia. She brings claims based on the
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`death of her son, John Doe 142, as well as her own injuries.
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`76.
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`Plaintiff Jane Doe 150 is a resident and citizen of Colombia. She brings claims based on the
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`death of her brother, John Doe 143, as well as her own injuries.
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`10
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`77.
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`Plaintiff Jane Doe 151 is a resident of and citizen of Colombia. She brings claims based on
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`the death of her husband, John Doe 199, and her sons, John Doe 180, John Doe 210, and John Doe
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`154, as well as her own injuries.
`
`78.
`
`Plaintiff John Doe 144 is a resident and citizen of Colombia. He brings claims based on the
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`death of his partner, Jane Doe 152, as well as his own injuries.
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`79.
`
`Plaintiff John Doe 145 is a resident and citizen of Colombia. He brings claims based on the
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`death of his mother, Jane Doe 155, as well as his own injuries.
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`80.
`
`Plaintiff Jane Doe 156 is a resident and citizen of Colombia. She brings claims based on the
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`death of her son, John Doe 146, as well as her own injuries.
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`81.
`
`Plaintiff Jane Doe 157 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 147, as well as her own injuries.
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`82.
`
`Plaintiff Jane Doe 158 is a resident and citizen of Colombia. She brings claims based on the
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`death of her son, John Doe 148, as well as her own injuries.
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`83.
`
`Plaintiff Jane Doe 159 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 149, as well as her own injuries.
`
`84.
`
`Plaintiff Jane Doe 161 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 151, as well as her own injuries.
`
`85.
`
`Plaintiff Jane Doe 162 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 152, as well as her own injuries.
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`86.
`
`Plaintiff Jane Doe 163 is a resident and citizen of Colombia. She brings claims based on the
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`death of her brother, John Doe 153, and her father, John Doe 231, as well as her own injuries.
`
`87.
`
`Plaintiff Jane Doe 165 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 155, as well as her own injuries.
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`11
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`88.
`
`Plaintiff Jane Doe 166 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 156, as well as her own injuries.
`
`89.
`
`Plaintiff Jane Doe 167 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 157, as well as her own injuries.
`
`90.
`
`Plaintiff Jane Doe 168 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 158, as well as her own injuries.
`
`91.
`
`Plaintiff Jane Doe 170 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her sister, Jane Doe 169, and her brother-in-law, John Doe 201, as well as her own injuries.
`
`92.
`
`Plaintiff Jane Doe 171 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 159, as well as her own injuries.
`
`93.
`
`Plaintiff Jane Doe 172 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 160, as well as her own injuries.
`
`94.
`
`Plaintiff John Doe 162 is a resident and citizen of Colombia. He brings claims based on the
`
`death of his son, John Doe 161, as well as his own injuries.
`
`95.
`
`Plaintiff Jane Doe 173 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 163, as well as her own injuries.
`
`96.
`
`Plaintiff Jane Doe 174 is a resident and citizen of Colombia. She brings claims based on the
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`deaths of her father, John Doe 164, and her brothers, John Does 182 and 196, as well as her own
`
`injuries.
`
`97.
`
`Plaintiff Jane Doe 177 is a resident and citizen of Colombia. She brings claims based on the
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`death of her son, John Doe 167, as well as her own injuries.
`
`98.
`
`Plaintiff Jane Doe 180 is a resident and citizen of Colombia. She brings claims based on the
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`death of her brother, John Doe 168, as well as her own injuries.
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`99.
`
`Plaintiff Jane Doe 181 is a resident and citizen of Colombia. She brings claims based on the
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`death of her partner, John Doe 169, as well as her own injuries.
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`100. Plaintiff Jane Doe 182 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 170, as well as her own injuries.
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`101. Plaintiff Jane Doe 183 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 171, as well as her own injuries.
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`102. Plaintiff Jane Doe 184 is a resident and citizen of Colombia. She brings claims based on the
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`death of her son, John Doe 172, as well as her own injuries.
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`103. Plaintiff Jane Doe 185 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 173, as well as her own injuries.
`
`104. Plaintiff Jane Doe 186 is a resident and citizen of Colombia. She brings claims based on the
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`death of her husband, John Doe 174, and her partner, John Doe 232, as well as her own injuries.
`
`105. Plaintiff Jane Doe 187 is a resident and citizen of Colombia. She brings claims based on the
`
`deaths of her brother, John Doe 175, and her father, John Doe 176, as well as her own injuries.
`
`106. Plaintiff Jane Doe 188 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 177, as well as her own injuries.
`
`107. Plaintiff Jane Doe 189 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 178, as well as her own injuries.
`
`108. Plaintiff Jane Doe 190 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 179, as well as her own injuries.
`
`109. Plaintiff Jane Doe 192 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 181, as well as her own injuries.
`
`110. Plaintiff Jane Doe 194 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her mother, Jane Doe 195, as well as her own injuries.
`
`
`
`13
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`

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`Case 2:20-cv-03244-WJM-MF Document 1 Filed 03/25/20 Page 14 of 168 PageID: 14
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`111. Plaintiff Jane Doe 196 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her husband, John Doe 183, as well as her own injuries.
`
`112. Plaintiffs Jane Doe 197 and Jane Doe 236 are residents and citizens of Colombia. They bring
`
`claims based on the death of their family member, John Doe 184, as well as their own injuries.
`
`113. Plaintiff Jane Doe 198 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 185, as well as her own injuries.
`
`114. Plaintiff Jane Doe 199 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 186, as well as her own injuries.
`
`115. Plaintiff Jane Doe 200 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 187, as well as her own injuries.
`
`116. Plaintiff Jane Doe 201 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her father, John Doe 188, as well as her own injuries.
`
`117. Plaintiff Jane Doe 202 is a resident and citizen of Colombia. She brings claims based on the
`
`deaths of her son, John Doe 204, and her partner, John Doe 189, as well as her own injuries.
`
`118. Plaintiff Jane Doe 203 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 190, as well as her own injuries.
`
`119. Plaintiff Jane Doe 204 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her mother, Jane Doe 205, as well as her own injuries.
`
`120. Plaintiff Jane Doe 206 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 191, as well as her own injuries.
`
`121. Plaintiffs Jane Doe 207 and John Doe 233 are residents and citizens of Colombia. Jane Doe
`
`207 brings claims based on the deaths of her parents, John Doe 192 and Jane Doe 208, her brother,
`
`John Doe 207, and her partner, John Doe 208, as well as her own injuries. John Doe 233 brings
`
`claims based on the death of his father, John Doe 208, as well as his own injuries.
`
`
`
`14
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`

`

`Case 2:20-cv-03244-WJM-MF Document 1 Filed 03/25/20 Page 15 of 168 PageID: 15
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`
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`122. Plaintiff Jane Doe 209 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 193, as well as her own injuries.
`
`123. Plaintiff Jane Doe 210 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 194, as well as her own injuries.
`
`124. Plaintiff Jane Doe 193 is a resident and citizen of Colombia. She brings claims based on the
`
`deaths of her daughter, Jane Doe 212, and her son-in-law, John Doe 209, as well as her own injuries.
`
`125. Plaintiff Jane Doe 179 is a resident and citizen of Colombia. She brings claims based on the
`
`deaths of her sons, John Does 197, 198 and 200, as well as her own injuries.
`
`126. Plaintiff Jane Doe 191 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 202, as well as her own injuries.
`
`127. Plaintiff Jane Doe 178 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her father, John Doe 203, as well as her own injuries.
`
`128. Plaintiff Jane Doe 237 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 234, as well as her own injuries.
`
`129. Plaintiff Jane Doe 238 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her husband, John Doe 235, as well as her own injuries.
`
`130. Plaintiff Jane Doe 239 is a resident and citizen of Colombia. She brings claims based on the
`
`deaths of her sons, John Doe 236 and John Doe 237, as well as her own injuries.
`
`131. Plaintiff Jane Doe 240 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 238, as well as her own injuries.
`
`132. Plaintiff Jane Doe 241 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her stepson, John Doe 239, as well as her own injuries.
`
`133. Plaintiff Jane Doe 242 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 240, as well as her own injuries.
`
`
`
`15
`
`

`

`Case 2:20-cv-03244-WJM-MF Document 1 Filed 03/25/20 Page 16 of 168 PageID: 16
`
`
`
`134. Plaintiff Jane Doe 243 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her husband, John Doe 241, as well as her own injuries.
`
`135. Plaintiff Jane Doe 244 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her husband, John Doe 242, as well as her own injuries.
`
`136. Plaintiff Jane Doe 245 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 243, as well as her own injuries.
`
`137. Plaintiff Jane Doe 246 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 244, as well as her own injuries.
`
`138. Plaintiff Jane Doe 247 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 245, as well as her own injuries.
`
`139. Plaintiff Jane Doe 248 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 246, as well as her own injuries.
`
`140. Plaintiff Jane Doe 249 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 247, as well as her own injuries.
`
`141. Plaintiff Jane Doe 250 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her father, John Doe 248, as well as her own injuries.
`
`142. Plaintiff Jane Doe 251 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 249, as well as her own injuries.
`
`143. Plaintiff Jane Doe 252 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 250, as well as her own injuries.
`
`144. Plaintiff Jane Doe 253 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 251, as well as her own injuries.
`
`145. Plaintiff Jane Doe 254 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her partner, John Doe 252, as well as her own injuries.
`
`
`
`16
`
`

`

`Case 2:20-cv-03244-WJM-MF Document 1 Filed 03/25/20 Page 17 of 168 PageID: 17
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`
`
`146. Plaintiff Jane Doe 255 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her husband, John Doe 253, and her son, John Doe 254, as well as her own injuries.
`
`147. Plaintiff Jane Doe 256 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her brother, John Doe 255, as well as her own injuries.
`
`148. Plaintiff Jane Doe 257 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her uncle, John Doe 256, as well as her own injuries.
`
`149. Plaintiff John Doe 258 is a resident and citizen of Colombia. He brings claims based on the
`
`death of his brother, John Doe 257, as well as his own injuries.
`
`150. Plaintiff Jane Doe 258 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John Doe 259, as well as her own injuries.
`
`151. Plaintiff Jane Doe 259 is a resident and citizen of Colombia. She brings claims based on the
`
`death of her son, John

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