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Government Exhibit # 1ST AMENDED COMPLAINT
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EXTRACTED KEY WORDS
CHEMICALS DRUMS CHEMICAL AGENT UMCD FIRST AMENDED COMPLAINTJAMES CONTAINERS DEFENDANTS MCCANDLISH PHILIP TRANSPORT ADVERSE HEALTH EFFECTS EXPOSURE WEAPONS WASTE SOIL MATERIALS SEVERE EXPOSE PHILIP EMPLOYEES TRAILER SUBSTANCES IMPURITIES TRUCK ENVIRONMENT INJURIES CMS MUSTARD BYPRODUCTS UNLOAD |
1 James E. McCandlish
Attorney at Law
2 111 SW Naito Parkway 2nd Floor
Portland OR 97204
3 Telephone: 503-224-2349
Facsimile: 503-224-3634
4 E-mail: j@mccandlish.com
OSB No. 75246
5 See signature page for a complete list of counsel
6 submitting document for filing. LR 10.2.
7 Attorneys for Plaintiff
8
9 UNITED STATES DISTRICT COURT
10 DISTRICT OF OREGON
11 Portland Division
12 RICHARD CARRAS ) Case No.
)
13 Plaintiff, )) FIRST AMENDED
14 ) COMPLAINT
vs. )
15 ) Personal Injury
CONTAINER MANAGEMENT ) (28 U.S.C. § 1332)
16 SERVICES, LLC, a California Limited Liability )
Company and PHILIP SERVICES ) DEMAND FOR JURY TRIAL
17 CORPORATION, INC., a Delaware Corporation ))
18 Defendant. )
19
20 PURPOSE
21 1. The purpose of this First Amended Complaint is to clarify facts alleged in the
22 original Complaint and to bring additional claims against defendants based in the same pattern
23 of facts and occurrences as described in the original Complaint.
24 PARTIES
25 2. At the time of his injury plaintiff Richard Carras was employed as a long haul
26 truck driver. On August 21, 1998, plaintiff was tasked to pick up several hundred fifty-five
Page 1 - FIRST AMENDED COMPLAINTJames E. McCandlish
Attorney at Law
111 SW Naito Parkway, Second Floor
Portland, Oregon 97204-3500
(503) 224-2348 FAX (503) 224-3634
1 (55) gallon steel drums for transport from the Army's Umatilla Chemical Depot (UMCD)
2 near Hermiston, Oregon to Portland, Oregon. Plaintiff brings suit against two companies
SNIPPETS:
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