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                                              EXHIBIT A
                                              PAGE 1 OF 7 PAGES

             IN THE CIRCUIT COURT OF GREENE COUNTY, MISSOURI
                               Division IV

MARIE ANN O'HARA

      Plaintiff
v.
                                              Case No. CV1912880

SOUTHWEST BAPTIST UNIVERSITY;
TERRY L. CAMPBELL d/b/a/ CAMPBELL
PEST CONTROL; and DELMAR E.
CAMPBELL and MARY K. CAMPBELL
d/b/a CAMPBELL PEST CONTROL,                             

      Defendants.

                     SECOND AMENDED PETITION

     COMES NOW the plaintiff Marie Ann O'Hara and for her cause 
of action
against defendants, and each of them, alleges and states
and follows:
1. Plaintiff Marie Ann O'Hara (hereinafter referred to as "Marie") is a resident of Polk County, Missouri. 2. Defendant Southwest Baptist University (hereinafter referred to as "SBU") is a Missouri corporation located in Polk County, Missouri. Service of process can be had upon at Wayne Gott, Acting Chief Executive Officer, Southwest Baptist University, 1601 South Springfield Street, Bolivar, MO. 3. Defendant Mary K. Campbell d/b/a Campbell Pest Control (hereinafter referred to as "Campbell") is a resident of Greene County, Missouri. She can be served at [address deleted], Springfield, Missouri, of at Campbell Pest Control's place of business, 2821 W. Division St., Springfield, Missouri. 4. Defendant Delmar E. Campbell d/b/a/ Campbell Pest Control (hereinafter referred to as "Campbell") is a resident of Greene County, Missouri. He can be served at [address deleted], Springfield, Missouri. 5. Defendant Terry L. Campbell d/b/a/ Campbell Pest Control (hereinafter referred to as "Campbell") is a resident of Greene County, Missouri. He can be served at [address deleted], Springfield, Missouri, or at Campbell Pest Control's place of business, 2821 W. Division St., Springfield, Missouri. 6. Venue in Greene County is proper pursuant to R.S.Mo 508.010 (2). 7. Marie was initially enrolled as a student of defendant SBU from August 1977 until 1982. During this time, Marie lived in campus dormitories and attended classes in buildings, all of which were owned and maintained by defendant SBU. 8. Marie re-enrolled as a student at SBU in the fall of 1988. 9. Marie was on the SBU campus periodically between 1982 and 1988. 10. From 1977 through 1989, defendant Terry L. Campbell d/b/a Campbell Pest Control, who, by and through their employees applied pesticides in the dormitories and other student services buildings and administrative building on its campus. 11. Between the fall of 1977 and 1982, while living in dormitories and attending classes in buildings all maintained by defendant SBU, Marie was continuously and repeatedly exposed to the residual pesticide that was applied by defendants Delmar E. Campbell and Mary K. Campbell d/b/a/ Campbell Pest Control, by and through their employees including defendant Terry L. Campbell, when she attended classes, lived in the dormitories and entered other buildings on the SBU campus. 12. Between the fall of 1977 and 1982, Marie would periodically become ill upon entering or while in a building on the SBU campus. She experienced symptoms ranging from mild flu symptoms to symptoms of irritability, dizziness, lethargy, numbness in her extremities, nauseousness, muscle cramps, and arm and back pain. These symptoms were transient, and Marie did not know what caused the symptoms. 13. After Marie left the SBU campus in the summer of 1982, the transient symptoms described in the previous paragraph, subsided. -2- 14. In October 1986, Marie was on the SBU campus and she entered the Student Union. She became very anxious and irritable, and had to leave the building. These symptoms
subsided when she left the building. Marie did not know what
caused these symptoms.
15. In November 1986, Marie was in the SBU campus library. Her face and ears turned red and hot, and she experienced shortness of breath, dizziness and extreme weakness. She left the library and these symptoms subsided, but she began experiencing flu-type symptoms (sweating, dizziness, nausea, fatigue, muscle cramping, weakness in her shoulders and legs), These symptoms persisted through December 1986, at which time they subsided. Marie did not know what caused these symptoms. 16. The illnesses and symptomology Marie experienced between September 1977 and June 1987 while on the SBU campus were caused by exposures to pesticides applied by defendants Delmar and Mary K. Campbell d/b/a Campbell Pest Control pursuant to Campbell's service arrangement with defendant SBU. 17. Marie's repeated exposures to pesticides applied by defendants Delmar and Mary K. Campbell d/b/a Campbell Pest Control at the direction of defendant SBU effectively weakened her system and made her susceptible to substantial injury and systemic damage from further pesticide exposure. 18. In September 1988, while attending class in the Casebolt Science Center on the SBU Campus, Marie was exposed to pesticides being sprayed by employees of defendant Terry L. Campbell d/b/a Campbell Pest Control at the request of defendant SBU. 19. Marie suffered a violent reaction to this exposure to pesticide, causing immediate symptoms including vomiting, swollen red eyes and face, burning throat, burning of lungs, difficulty breathing, nose bleeds, disorientation, slurred speech, blurred vision and numbness. Marie reported her reaction to the pesticide and her symptoms to defendant SBU. Her symptoms improved, but did not completely subside. -3- 20. Marie questioned defendant SBU regarding the safety of the pesticides applied by defendant Terry L. Campbell d/b/a Campbell Pest Control. Marie also sought information concerning the identity and hazards associated with these pesticides, and was informed only that the pesticides were safe. She was provided with no other information. 21. Subsequent to the September 1988 exposure, defendant SBU contacted defendant Terry L. Campbell d/b/a Campbell Pest Control and instructed Campbell to not spray pesticides on its campus during business hours when students, employees and other members of the public were present. 22. In January 1989, while in the Administration Building, Marie was again exposed to pesticides administered during business hours by employees of defendant Terry L. Campbell d/b/a Campbell Pest Control. Marie again suffered a violent reaction to the pesticide, causing immediate symptoms including those symptoms referred to in paragraph 17 as well as burns to her lungs and difficulty breathing. Her symptoms have not subsided, but have become permanent and disabling. 23. Defendant SBU was negligent in: a. Failing to maintain its buildings in a reasonably safe condition by utilizing chemical pesticides which present a serious risk of injury while persons were present; b. Authorizing and/or directing defendant Campbell to SBU buildings during times when students, faculty, employees and other members of the public; c. Failing to warn Marie, other students, faculty members, employees and members of the public when pesticides were going to be applied in SBU buildings, and of the dangerous risks associated with said pesticides; d. Failing to provide adequate indoor air quality in its buildings by authorizing and/or directing the use of pesticides when Marie, other -4- students, faculty members, employees and/or members of the public were going to be present in the buildings. 24. Defendants Delmar and Mary K. Campbell d/b/a/ Campbell were negligent in: a. Failing to warn of the health dangers presented by the pesticide it applied in SBU buildings; b. Applying pesticide in SBU buildings at times when students, faculty, employees and other members of the public were present; and c. Spraying pesticide in SBU buildings with people present when it knew or should have known that some persons develop severe reactions to pesticides; and d. Applying pesticides on the SBU Campus during business hours after it had been warned that the pesticides were harmful to plaintiff and after SBU had instructed Campbell not to apply pesticides on its campus during business hours. 25. Defendant Terry L. Campbell d/b/a Campbell Pest Control was negligent in: a. Failing to warn of the health dangers presented by the pesticide it applied in SBU buildings; b. Applying pesticide in SBU buildings at times when students, faculty, employees and other members of the public were present; and c. Spraying pesticide in SBU buildings with people present when it knew or should have known that some persons develop severe reactions to pesticides; and d. Applying pesticides on the SBU Campus during business hours after it had been warned that the pesticides were harmful to plaintiff and after SBU had instructed Campbell not to apply pesticides on its campus during business hours. -5- 26. As a direct and proximate result of defendant's negligence, Marie suffered severe and permanent damage to her immune system; central nervous system; internal organs; visual/ motor abilities; senses of touch, smell, and hearing; respiratory system; circulatory systems; genitourinary system; gastrointestinal system; eyes, ears, nose, and throat; skeletal system autonomic nervous system; reproductive system; and cardiovascular system. Marie now suffers from a chemically acquired immune disorder, toxic encephalopathy and multiple chemical sensitivity in which she has become hypersensitive to nearly all commonly encountered chemicals, resulting in severe and volatile reactions requiring her complete isolation. She has been rendered nervous, has suffered pain and anxiety of the body and mind, and she has experienced emotional upset and personality changes. She has suffered all of the above injuries, pain and damages since the date of the events described herein, suffers them at the present time and will suffer them in the future; said injuries, pain and damages are permanent, disabling and progressive. 27. By reason of her injuries, Marie has paid or become obligated for, and will in the future pay or become obligated for, items of expense in obtaining and receiving medical care and treatment. 28. Prior to the aforesaid injuries, Marie was an able- bodied woman capable of doing and performing work and labor. As a direct and proximate result of her injuries, she has and in the future will suffer loss of wages, earnings, salaries and profits; and she has and in the future will suffer an impairment and diminished capacity for work, labor and pleasure. 29. Pursuant to R.S.Mo 408.040.2, Marie mailed a certified letter to defendant SBU and Campbell Pest Control on August 8, 1991, offering to settle her claims against all defendants if the offer was accepted with 60 days. 30. Defendant SBU, defendants Delmar E. Campbell and Mary K. Campbell d/b/a Campbell Pest Control, and defendant Terry L. Campbell d/b/a Campbell Pest Control have not accepted Marie's settlement offer. Therefore, Marie is entitled to prejudgment interest at the statutory rate from October 9, 1991, on any judgment against defendant SBU and/or -6- defendants Delmar E. Campbell and Mary K. Campbell d/b/a Campbell Pest Control, and/or Terry L. Campbell d/b/a Campbell Pest Control, if the amount of that judgment exceeds the amount of the settlement offer. 31. Plaintiff is suing multiple defendants and is alleging that their joint actions caused and/or contributed to cause Marie's injuries, and therefore plaintiff is requesting apportionment of fault between defendants. WHEREFORE, Marie prays that she be awarded fair and reasonable damages against each defendant, prejudgment interest on said sum pursuant to R.S. Mo. 408.040.2 at the statutory rate on and after the date of rejection of the offer if prior to October 9, 1991, or from October 9, 1991, and for her costs herein expended. STRONG & ASSOCIATES, P.C. By [original copy signed] Thomas Strong - MoBar #16173 By [original copy signed] Steven Harrell - MoBar #35959 901 East Battlefield Springfield, Missouri 65807 417/887-4300 Attorneys for Plaintiff CERTIFICATE OF SERVICE I hereby certify that the foregoing document was served upon all attorneys of record for each of the parties to the action by mailing a copy to their respective offices, as prescribed by law, on the 9th day of July 1992. STRONG & ASSOCIATES, P.C. [original copy signed by Steven Harrel] -7-

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