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- � I <br /> { � I <br /> 1 <br /> e. -In allowing said tree to present a danger or create a <br /> 2 Hazard for the public traveling on Jefferson Street at said point. <br /> 3 f. In allowing the subject tree to hang out over Jefferson <br /> 4 Street in a dangerous fashion as to unreasonably interfere with the <br /> 5 safe travel of Michael Alan Wood on Jefferson Street. <br /> 6 g. By allowing said tree to project over the travelled <br /> 7 portion of Jefferson Street in such a manner to cause a hazard to <br /> 8 the public travelling on Jefferson street and in particular, <br /> 9 Michael Alan Wood. <br /> 10 8. <br /> 11 I As a result of the defendants' negligence in one or more of <br /> 12 the particulars alleged, the limb on the subject tree fell onto the <br /> 13 vehicle operated by Michael Alan Wood, killing him. <br /> 14 9. <br /> 15 I By reason of the death of Michael Alan Wood on June 20, 1990 <br /> 16 there were necessarily incurred funeral expenses for funeral, <br /> 17 burial, and memorial services in a sum to be determined at the time <br /> 18 of trial to Plaintiff's damage. <br /> 19 10. <br /> 20 By reason of the death of Michael Alan Wood, the estate of <br /> 21 Michael Alan Wood has suffered pecuniary damages in the amount of <br /> 22 $300,000. <br /> 23 11. <br /> 24 By reason of the death of Michael Alan Wood, his father, <br /> 25 Delbert Wood, has suffered a pecuniary loss in the sum of $150,000 <br /> 26 and has lost the society, companionship, and services of his son <br /> LAW OF { CES <br /> OF <br /> A. DEAN OWENS <br /> 933 PEARL STREET <br /> GENE. OREGON 97401 -2799 <br /> 5636862907 COMPLAINT - Action at Law - Negligence - Wrongful Death -3- <br /> 1 <br />