CAROLE AND JOHN ANTHONY PRICE, | IN THE
surviving parents of John Joseph Price, |
and personal representatives of the | CIRCUIT COURT
ESTATE OF JOHN JOSEPH PRICE, |
3403 Millie Way | FOR
Manchester, Maryland 21102 || BALTIMORE CITY
Plaintiffs, |
v. | CASE NO. _______________
|
STURM, RUGER & COMPANY, INC., |
1 Lacey Place |
Southport, Connecticut 06490, ||
Serve on Maryland SDAT: |
301 W. Preston Street |
Room 801 |
Baltimore, Maryland 21201-2395 ||
FALLSTON GUN AND PAWN, INC. |
2800 Bel Air Road |
Fallston, Maryland 21047, ||
Serve on Registered Agent: |
Robert Scheuerman |
2800 Belair Road |
Fallston, Maryland 21047 ||
DENNIS J. DANIELCZYK, JR., |
3806 Pinedale Drive |
Baltimore, Maryland 21236, ||
LARRY ALEXANDER, |
2009 Windys Run Road |
Catonsville, Maryland 21228, and ||
PHILLIP ALEXANDER, |
1925 Hillenwood Road |
Baltimore, Maryland 21239, ||
Serve on both minor and parent: |
Phillip and Phyllis Alexander |
1925 Hillenwood Road |
Baltimore, Maryland 21239, ||
Defendants. |
COMPLAINT
(Wrongful Death, Survival Actions: Product Liability, Negligence, Breach of Warranty)
Plaintiffs Carole and John Anthony Price, as surviving parents of John Joseph Price, and
as personal representatives of the Estate of John Joseph Price, by their undersigned attorneys, sue
defendants, and allege:
SNIPPETS:
as personal representatives of the Estate of John Joseph Price, by their undersigned
This is a product liability, negligence and breach of warranty action arising out of the
handgun that lacked adequate safety devices and warnings.
The shooting occurred on August 20,
Middle School in Baltimore.
Mr. Danielczyk owned a handgun,
with an empty magazine in the gun but a live round still concealed in the
to include safety features and adequate warnings with the gun used to kill John Joseph Price.
which were known to Ruger and Fallston before the gun in this case was
Phillip Alexander, and thus prevented the killing of John Joseph Price.
defendants accountable for causing their son's death.
Carole and John Anthony Price are adult residents of Manchester,
are the surviving parents of John Joseph Price, and the personal representatives of his
Mr. Danielczyk kept the Ruger 9 mm gun and two ammunition magazines in his
in an area inaccessible to unauthorized users like Phillip Alexander.
failed to incorporate reasonable, feasible safety devices or adequate warnings to prevent its
This complaint is timely filed within three years of John's death pursuant to § 3904of the
COUNT I PRODUCT LIABILITY, DESIGN DEFECT, WRONGFUL DEATH (RUGER
Plaintiffs claim all damages available to them under the Maryland Wrongful Death
COUNT II PRODUCT LIABILITY, DESIGN DEFECT, SURVIVAL ACTION (RUGER,
Paragraphs 1-40 and 43-45 are incorporated by reference and realleged as if fully set
reasonable care in selling the gun not to expose others to reasonably foreseeable risks of
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