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1 the owner of property described in exhibit A attached hereto and <br /> 2 otherwise described as the property located on the west side of <br /> 3 Jefferson Street in Eugene, Lane County, Oregon just North of the <br /> 4 alley between Broadway and 10th Avenue. <br /> 5 <br /> 5. <br /> 6 On June 20, 1990 deceased, Michael Alan Wood was operating his <br /> 7 vehicle in a southerly direction on Jefferson Street between <br /> 8 Broadway and 10th Avenue in Eugene, Lane County Oregon heading in <br /> 9 a southerly direction when at said time a limb broke from a tree <br /> 10 located between the sidewalk and Jefferson St. on the property <br /> 11 described in Exhibit A and fell onto the vehicle operated by <br /> 12 Michael Alan Wood killing Michael Alan Wood. <br /> 13 6. <br /> 14 Jefferson Street at the location described is a paved public <br /> 15 street within the city limits of the City of Eugene and is main - <br /> 16 tained by the City of Eugene. <br /> 17 7. <br /> 18 At said time and place the Defendants were negligent in one or <br /> 19 more of the following particulars. <br /> 20 a. In failing to properly trim the heavy foliage ladened <br /> 21 branch tips of said tree. <br /> 22 b. In failing to remove all broken stubs from said tree. <br /> 23 c. In failing to properly cable the main trunks of said tree. <br /> 24 d. In failing to properly inspect said tree for and remove <br /> 25 limbs from said tree which posed a reasonable risk of breaking onto <br /> 26 the traveled street. <br /> LAW OFFICES <br /> Of <br /> A. DEAN OWENS <br /> all PEARL. STREET <br /> EUGENE OREGON Q7401 -2Taa <br /> 600-806-2807 COMPLAINT - Action at Law - Negligence - Wrongful Death -2- <br />