IN THE UNITED
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FOR THE NORTHERN
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EASTERN
MARTHA K. BENFORD, HARRY
BENFORD, III, DAVID HAYS, AURELIO
FERNANDEZ-CONCHES0 and
GERERDO SUBERO PULGAR individually
and on behalf of all others similarly
situated,
Plaintiffs,
V.
BRIDGESTONE CORPORATION, a foreign
corporation, BRlDGESTONElFlRESTONE,
INC., an Ohio corporation,
BRIDGESTONEIFIRESTONE, INC.,
Division, and FORD MOTOR COMPANY, a )
Delaware corporation,
Defendants.
SECOND AMENDED CLASS ACTION COMPLAINT
NOW COME the Plaintiffs, MARTHA K. BENFORD, HARRY
111, DAVID HAYS, AURELIO
O
SUBERO PULGAR, individually and on behalf of all others
(hereafter referred to as "Plaintiffs") by and through their
B.
MOLL&ASSOCIATES, LTD., and
CORPORATION, a foreign corporation, (hereafter referred to
BRIDGESTONE/FIRESTONE, INC., an
9~;~,;~;;~, "FIRESTONE") BRlDGESTONE:/FlRESTONE,
eafter
Thee
Filll Nalimd
SNIPPETS:
due to an increased risk of tread separation,
separation and other tire failure associated with these tires.
over 101 fatalities and over 400 reported injuries in the United States.
recall of all defective tires, including the current recall of 15 inch ATX and ATX
tires manufactured at any of the 7 North American plants, all Firehawk ATX, ATX
23 Degree, Widetrack Radial Baja, Widetrack Radial Baja A/S, Wilderness HT tires,
and the Steeltex R4$ and Steeltex PJT light truck tires, as well as to ensure
On or about said date, the Firestone tires on the Chevrolet Blazer
driven by Plaintiff experienced a tire tread separation which caused the Chevrolet
Ford Explorer that was equipped with Firestone tires.
Plaintiffs sustained severe injuries, including the loss of his right hand
Firestone tires and widespread safety concerns regarding these vehicles,
tires were also sold in the aftermarket and may be on any light truck or SUV.
subject to entry of an order certifying this cause as a Class Action
distributed by Defendants.
Code Ann, Tit, 6,2513; D,C, Code Ann.
intended and/or advertised use, due to defective manufacturing.
Section 2 of the "Uniform Deceptive Trade Practices Act",
permanent injuries, both externally and internally, and were and will be hindered
sums of money for medical care and services endeavoring to become healed and
Jnsafe and defective conditions of said products,
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