Cruz Morales

$1,750,000

Net to client: $1,043,052

On or about December 15, 2004, decedent was employed by Defendant Site Concrete, Inc. and working on property owned and/or occupied by Defendant L109 McKinney Investments, LTC. Pursuant to the contract between Defendants Site Concrete, Inc. and L109 McKinney Investments, LTD., Defendant Melissa Northcreek, LTD. Was Defendant L109 McKinney Investments, LTD,’s representative on that job site and in charge of the entire project and the hiring of contractors. Also pursuant to the contract between Defendants Site Concrete, Inc. and L109 McKinney Investments, LTC., Defendant Site Concrete, Inc. hired Defendant Ronald H. Jessen DBA Tren-Tech Company to prepare a trench engineering safety report for that job site, and Defendant Ronald H. Jessen hired Defendant John W. Anderson to submit that signed report as MR. Anderson is a licensed and registered Professional Engineer.

While in the course and scope of his employment on said date, decedent was in a deep trench which, in Plaintiffs’ information and belief, had been dug by one or more employees and/or authorized agents of Defendant Site Concrete, Inc. when its sides suddenly collapsed. In this collapse, a great deal of dirt and rocks fell on top of decedent, pinning him under their weight and suffocating him to death. Decedent’s supervisor(s), who were also Defendants’ employees and/or authorized agents, instructed decedent to work in that trench even though decedent’s supervisor(s) knew or reasonable should have known that the trench was an unreasonably dangerous work-place and that trench excavations are inherently dangerous.