TIPTON v. MORRIS et al

Filing 143

ORDER ON DEFENDANT DLS'S MOTION FOR SUMMARY JUDGMENT - The Court DENIES Defendant 107 DLS's Motion for Summary Judgment. (See Order.) Signed by Judge Larry J. McKinney on 11/15/2016. Copies distributed per distribution list. (LDH)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF INDIANA
INDIANAPOLIS DIVISION

GREGORY LACY,
Plaintiff,
vs.
TIME DISPATCH SERVICES, INC., et al.,
Defendants.

ZACHARY WRIGHT,
Plaintiff,
vs.
TIME DISPATCH SERVICES, INC., et al.,
Defendants.
__________________________________

MISTIKAE ELIZABETH TIPTON,
Plaintiff,
vs.
PAUL T. MORRIS, et al.,

Defendants.
__________________________________

1

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

No. 1:12-cv-00819-LJM-DKL

No. 1:12-cv-01032-LJM-DKL

No. 1:12-cv-01476-LJM-DKL

ORDER ON DEFENDANT DLS’S MOTION FOR SUMMARY JUDGMENT
This matter comes before the Court on Defendant DLS Logistics, LLC’s (“DLS”)
three separate Motions for Summary Judgment on the claims of negligence brought
against it by Plaintiffs Gregory Lacy, Zachary Wright, and Mistikae Elizabeth Tipton
(collectively “Plaintiffs). Each of the Plaintiffs alleges negligence against DLS, Time
Dispatch Service, Inc. (“TDS”), and Paul Morris, following an accident in which a vehicle
driven by Morris allegedly resulted in injuries to each of the Plaintiffs. 1
For the reasons set forth below, the Court DENIES DLS’s Motion for Summary
Judgment.
I.

BACKGROUND

A. RELATIONSHIP BETWEEN DLS AND TDS
Thomas “Cecil” Dennis is the sole owner of DLS. Dennis Dep. 18:17-18. DLS is
in the trucking business and facilitates the movement of goods through dispatching and
labor if it utilizes its own trucks. Id. 41:8-17. TDS is a motor carrier similar to DLS, but
rather than employ its own drivers or purchase trucks, it relies on contracted agents, like
DLS, to solicit business under its United States Department of Transportation (“DOT”)
authority. Dunn Dep. 26:14-23.
On April 21, 2010, DLS and TDS signed an Agent Agreement wherein DLS acted
as TDS’s agent and solicited “interstate and intrastate shipments of property for
transportation in interstate and intrastate commerce.” Dennis Dep. Pl.’s Ex. 26, ¶ 1
(hereinafter “Agent Agreement”). DLS was also responsible for “provid[ing] personnel,

1 Each of the Plaintiffs brought a separate cause of action against DLS, TDS, and Morris. DLS moved for
summary judgment against all three Plaintiffs on the same grounds and filed the same brief in each cause
of action. Accordingly, the Court consolidates its findings with respect to DLS’s motion in the interests of
time and efficiency.

2

office space and telephone equipment, at it’s [sic] expense sufficient to properly perform
as Agent for Time Dispatch Services.” Id. ¶ 5. DLS also warranted that it would ensure
compliance with the laws and regulations of the DOT. Id. In turn, TDS represented that
it was a Licensed Broker authorized by the DOT, which authorized brokerage and carrier
operations in interstate commerce. Id. TDS provided that it would “fully control and be
responsible for all shipments handled under its authority. As any shipment is solicited by
[DLS], the latter will inform Time Dispatch Services … of the origin and destination of said
shipment and, if brokered, the identity of carrier to be utilized.” Id. ¶ 3. The Agent
Agreement further provided that DLS would receive 85% of the gross revenue plus a 2%
bonus minus Lessor pay as compensation for its service. Id. ¶ 12.
In August 2011, DLS purchased a 1995 Freightliner Truck. Dennis Dep. 26:14-23.
On September 2, 2011, Dennis signed a TDS Truck Application Contract Operating
Agreement, which listed DLS as the contractor and TDS as the carrier. Dennis Dep. Pl.’s
Ex. 28 (hereinafter “Operating Agreement”). TDS did not sign the Operating Agreement.
Id.; Dennis Dep. 27:12-28:16. Nonetheless, TDS sent the hard license plate and the cab
card to DLS, which Dennis interpreted as validating the Operating Agreement. Dennis
Dep. 28:7-11. At Dennis’ instruction, DLS employee Paul Morris placed the TDS stickers
on the truck. Morris Depo. 127:2-128:21. The Operating Agreement states that “[TDS], a
for-hire motor carrier, operating under authority issued by the Interstate Commerce
Commission wishes to obtain transportation with equipment it does not own through an
agreement with [DLS].” Operating Agreement. It further stated that DLS agreed “to use
all necessary labor to transport, load, and unload on behalf of such other carriers as [TDS]
may designate.” Id., ¶ 1. Under the Operating Agreement, DLS received 75% of the gross

3

revenue of all loads. Id., ¶ 2. The Operating Agreement also stated that “[i]f an accident
claim arises out of the driver’s negligence the full responsibility of the claim with be [DLS]’s
responsibility.” Id., ¶ 3.
Dennis testified that the Operating Agreement meant that DLS operated under
TDS’s DOT number and that TDS acted as the operating authority responsible for the
load. Dennis Dep. 25:6-14. Dennis described TDS as a “silent partner banker,” stating
that TDS provided money up front along with insurance. Id. 40:24-41:7. In return, DLS
provided dispatching services for the shipment, unless one of its trucks was assigned the
task of delivering the shipment, as was the case the day of the accident, in which case it
would also provide the driver and the vehicle. Id. 41:8-17.
B. PAUL MORRIS’ EMPLOYMENT WITH DLS
Dennis hired Paul Morris to be a truck driver sometime in 2009. Morris Dep. 16:1623. At all times, Morris considered himself to be a DLS employee whose duty was to
drive DLS trucks. Id. 34:19-35:7; 58:5-11. Dennis paid Morris weekly in cash. Dennis
Dep. 52:1-5. Morris worked directly for Dennis and would do whatever task Dennis
required of him. Id. 35:17-22; Morris Dep. 34:19-35:7.

Morris stated that he only

answered to Dennis, who he considered one in the same with DLS. Morris Dep. 43:1444:10. In addition to driving trucks, Morris repaired and performed maintenance on DLS
equipment. Id. 49:5-10. Morris also stayed in DLS’s trailer and kept an eye on the
property. Id. 65:7-66:21. Dennis provided Morris a universal key that worked on most of
the Freightliner trucks. Dennis Dep. 36:11-18.

Morris stated that he “always had

permission to drive [Dennis’] vehicles” and that he was unaware of any of the insurance
issues with respect to the trucks on the lot. Morris Dep. 80:17-81:19. Morris believed that

4

he had permission to drive all DLS trucks, including the Freightliner involved in the
accident. Id. 76:5-16.
TDS approved Morris as a driver until he failed a drug screening, which resulted in
termination of his eligibility to drive for TDS. Id. 48:4-22; Dennis Dep. 119:8-120:12. TDS
sent Morris a letter indicating that he was disqualified from driving for TDS. Morris Dep.,
Def.’s Ex. 25. The letter stated that “DOT regulations require [TDS] to immediately
remove you from performing any DOT safety-sensitive duties, including, but not limited
to, Commercial Driving Duties. This disqualification applies to performing any type of
DOT safety-sensitive duties for any employer.” Id. The letter further admonished that, in
order to resume his driving privileges, Morris would have to be evaluated by a Qualified
Substance Abuse Professional. Id.
Morris did not receive the letter from TDS, but was informed by Dennis that he
could no longer drive for TDS. Morris Dep. 77:24-78:16.

Even after receiving this

information from Dennis, Morris believed he could still drive the TDS freight if so instructed
by Cecil. Id. 78:17-25. Indeed, approximately four months after the failed drug test, and
without approval from TDS or evaluation by a Qualified Substance Abuse Professional,
Morris resumed hauling TDS freight with Dennis’ permission. Id. 87:12-89:8. Dennis
admitted that Morris, following the failed drug test and receipt of the TDS disqualification
letter, had at least “pulled a few” TDS loads, although he could not recall how many.
Dennis Dep. 14:5-18. Morris stated, “Whatever [Dennis] wanted me to haul, I’d haul it.”
Morris Dep. 89:8. Morris only answered to Dennis and did not have contact with TDS
with respect to the hauling of TDS freight. Id. 88:13-22; 89:9-90:8. Dennis believed that

5

at all times Morris was acting within the course and scope of his employment with DLS.
Dennis Dep. 171:54-172:3.
Following Morris’ termination by TDS, DLS reinstated its DOT operating authority
and obtained insurance for a Volvo truck so that Morris could continue driving. Id. 34:4-9;
120:6-21. Dennis does not recall whether he disclosed Morris’ failed drug test to the
insurance company when he sought to insure the Volvo truck with Morris as the driver.
Id. 122:13-123: Morris replaced the TDS stickers with DLS stickers on the Volvo. Morris
Dep. 93:24-94:7.
C. SEPTEMBER 21, 2011 ACCIDENT
On September 21, 2011, Morris made a couple runs for Dennis in the Volvo. Id.
92:13-14. During the second run, the steering column on the Volvo fell into his lap. Id.
92:14-16. Morris informed Dennis that the Volvo’s steering wheel fell off and that the
“truck is done” and “that truck ain’t going nowhere.” Id. 100:17-22. Morris and Dennis
both went to evaluate the Volvo truck. Id. 100:23-25. Morris testified that fixing the truck
at that time of day was impossible. Id. 99:11-15. Because the Volvo was disabled, the
TDS-leased Freightliner was the only other truck available on September 21, 2011. Id.
74:18-20.
At approximately 9:00 p.m., Dennis informed Morris that a load needed to be
delivered by midnight. Id. 76:17-77. Another DLS employee and TDS-approved driver,
Tom Baker, could not be reached to transport the load, despite both Morris and Dennis’
efforts to contact him. Dennis Dep. 29:8-30:7. If the load was not delivered by midnight,
DLS could have received a penalty or potentially lost a customer. Id. 100:17-25. Morris
indicated that he could take the load, but reminded Dennis that he did not have a vehicle

6

at the time. Morris Dep. 74:6-9. In response, Dennis told Morris that the Volvo was not
the only truck on the lot and gave him permission to haul the load in the TDS-leased
Freightliner. Id. 74:21-75:10; Dennis Dep. 29:23-30:18. Morris believed that he had
permission to drive the Freightliner at all times. Id. 80:22-24.

As Dennis admitted,

however, he could not authorize Morris to drive the TDS-leased truck, the only available
truck at that time. Dennis Dep. 32:5-10; 45:16-24; 100:11-16. Dennis and Morris provided
conflicting accounts as to whether Dennis knew that the Volvo was inoperable on the
night of September 21, 2011, which left only the TDS-leased Freightliner truck available
to haul the load. Id. 100:14-16; 117:25-118:11; compare Morris Dep. 74:4-75:4;100:6-25.
That night, Morris began delivery of the load in the TDS-leased Freightliner tractor. Morris
Dep. 86:12-15; 90:17-22.
At approximately 11:40 p.m., Morris crashed the TDS-leased Freightliner truck into
the Plaintiffs. Id. 141:17-144:16. Immediately after the accident, Morris called Dennis to
report it. Id. 144:8-18.
II.

SUMMARY JUDGMENT STANDARD

As stated by the Supreme Court, summary judgment is not a disfavored
procedural shortcut, but rather is an integral part of the federal rules as a whole, which
are designed to secure the just, speedy, and inexpensive determination of every action.
See Celotex Corp. v. Catrett, 477 U.S. 317, 327, 106 S.Ct. 2548, 91 L.E.2d 265 (1986).
See also United Ass’n of Black Landscapers v. City of Milwaukee, 916 F.2d 1261, 126768 (7th Cir. 1990). Motions for summary judgment are governed by Federal Rule of Civil
Procedure 56(a), which provides in relevant part: The court shall grant summary judgment

7

if the movant shows that there is no genuine dispute as to any material fact and the
movant is entitled to judgment as a matter of law.
Once a party has made a properly-supported motion for summary judgment, the
opposing party may not simply rest upon the pleadings but must instead submit
evidentiary materials showing that a fact either is or cannot be genuinely disputed.
Fed.R.Civ.P. 56(c)(1). A genuine issue of material fact exists whenever “there is sufficient
evidence favoring the nonmoving party for a jury to return a verdict for that
party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249, 106 S.Ct. 2505, 91 L.Ed.2d
202 (1986). The nonmoving party bears the burden of demonstrating that such a genuine
issue of material fact exists. See Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475
U.S. 574, 586–87, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986); Oliver v. Oshkosh Truck
Corp., 96 F.3d 992, 997 (7th Cir.1996). It is not the duty of the Court to scour the record
in search of evidence to defeat a motion for summary judgment; rather, the nonmoving
party bears the responsibility of identifying applicable evidence. See Bombard v. Ft.
Wayne Newspapers, Inc., 92 F.3d 560, 562 (7th Cir.1996).
In evaluating a motion for summary judgment, the Court should draw all
reasonable inferences from undisputed facts in favor of the nonmoving party and should
view the disputed evidence in the light most favorable to the nonmoving party. See Estate
of Cole v. Fromm, 94 F.3d 254, 257 (7th Cir.1996). The mere existence of a factual
dispute, by itself, is not sufficient to bar summary judgment. Only factual disputes that
might affect the outcome of the suit in light of the substantive law will preclude summary
judgment. See Anderson, 477 U.S. at 248, 106 S.Ct. 2505; JPM Inc. v. John Deere Indus.
Equip. Co., 94 F.3d 270, 273 (7th Cir.1996). Irrelevant or unnecessary facts do not deter

8

summary judgment, even when in dispute. See Clifton v. Schafer, 969 F.2d 278, 281 (7th
Cir.1992). If the moving party does not have the ultimate burden of proof on a claim, it is
sufficient for the moving party to direct the court to the lack of evidence as to an element
of that claim. See Green v. Whiteco Indus., Inc., 17 F.3d 199, 201 & n. 3 (7th Cir.1994).
“If the nonmoving party fails to establish the existence of an element essential to his case,
one on which he would bear the burden of proof at trial, summary judgment must be
granted to the moving party.” Ortiz v. John O. Butler Co., 94 F.3d 1121, 1124 (7th
Cir.1996).
III.

DISCUSSION

DLS seeks summary judgment on three separate theories. It first argues that DLS
had fulfilled its role under the Agency Agreement and therefore cannot be held liable for
Morris’ actions after he left the DLS lot in the TDS-leased Freightliner. Similarly, DLS
suggests that Morris was acting as a “borrowed servant” for TDS at the time of the
collision. Finally, DLS contends that TDS is solely liable for the accident as its placards
were placed on the side of the Freightliner. All three theories may be resolved by
answering the following: what was Morris’ relationship with DLS at the time the collision
occurred? The Court finds that this question is best left to the province of the jury for the
following reasons.
A. TDS, DLS, AND MORRIS’ EMPLOYMENT RELATIONSHIP
DLS first argues that it completed its responsibilities under the Agency Agreement
after it provided the driver and equipment to TDS, at which point TDS assumed full control
and responsibility for the load and actions of Morris. DLS maintains that by and through

9

the Agency Agreement it negotiated with TDS, Morris and TDS developed a masterservant relationship thereby imputing Morris’ alleged negligence to TDS as the principal.
“Agency is a relationship resulting from the manifestation of consent by one party
to another that the latter will act as an agent for the former.” Smith v. Brown, 778 N.E.2d
490, 495 (Ind. Ct. App. 2002). Under Indiana law, “[t]o establish an actual agency
relationship, three elements must be shown: (1) manifestation of consent by the principal;
(2) acceptance of authority by the agent; and (3) control exerted by the principal over the
agent.” Bauermeister v. Churchman, 59 N.E.3d 969, 974 (Ind. Ct. App. 2016). The party
asserting the existence of an agency relationship bears the burden of proving its
existence. Id. “Whether an agency relationship exists is generally a question of fact, but
if the evidence is undisputed, summary judgment may be appropriate.” Demming v.
Underwood, 943 N.E.2d 878, 884 (Ind. Ct. App. 2011).
DLS fails to designate any evidence to establish that an agency relationship
existed between Morris and TDS. DLS’s attempt to utilize its own Agency Agreement
that it entered into with TDS for the proposition that Morris and TDS in turn developed an
agency relationship is unfounded. The Agency Agreement contemplates an agency
relationship between DLS and TDS and nothing more. Morris was not privy to, nor subject
to, the Agency Agreement. See Corry v. Jahn, 972 N.E.2d 907, 918 (Ind. Ct. App. 2012)
(“The agent must acquiesce to the arrangement and be subject to the principal’s
control.”). At all times both Morris and Dennis believed Morris to be acting under the
scope of his employment with DLS, not TDS. In fact, the record shows that TDS explicitly
prohibited Morris from driving on its behalf following his failed drug screening, yet DLS

10

provided him the authority to haul the load in question as it had a vested interest in the
timely delivery of the shipment.
Even assuming that an agency relationship existed between TDS and Morris, DLS
fails to explain how that fact would absolve DLS of its liability as Morris’ employer. Dennis
admitted that at all times Morris acted within the course and scope of his employment
with DLS, which, as the Plaintiffs and Morris highlight, could subject DLS to vicarious
liability. See Robbins v. Trs. of Ind. Univ., 45 N.E3d 1, 6 (Ind. Ct. App. 2015) (“Vicarious
liability will be imposed upon an employer under the doctrine of respondeat superior
where the employee has inflicted harm while acting within the scope of employment.”).
The doctrine of respondeat superior renders liable an employer that would not
otherwise be liable for its own acts, but nonetheless “can be held liable for the wrongful
acts of its employee which are committed within the scope of employment.” Knighten v.
E. Chi. Hous. Auth., 45 N.E.32 788, 792 (Ind. 2015) (internal quotation marks omitted).
An employee’s conduct will fall within the scope of employment if the act that causes the
injury is “incidental to the conduct authorized or it must, to an appreciable extent, further
the employer’s business.” Barnett v. Clark, 889 N.E.2d 281, 283 (Ind. 2008). “Acts for
which the employer is not responsible are those done on the employee’s own initiative.”
Stropes by Taylor v. Heritage House Childrens Ctr. of Shelbyville, Inc., 547 N.E.2d 244,
247 (Ind. 1989) (internal quotations omitted).
As already stated above, there is ample evidence to suggest that Morris could have
been acting in the course and scope of his employment with DLS. Morris acted at the
direction of DLS and for DLS’s direct benefit. Moreover, Dennis provided Morris the
authority to drive the load the night the accident occurred.

11

To overcome this hurdle, DLS attempts to establish that TDS “borrowed” Morris
for the duration of the haul and is therefore liable for his actions undertaken on TDS’s
behalf. Indiana recognizes that “an employee while generally employed by one party,
may be loaned to another in such a manner that the special employer may be responsible
for the acts of the employee under the doctrine of respondeat superior.” N.Y.C. Cent. R.R.
Co. v. N. Ind. Pub. Serv. Co., 221 N.E.2d 442, 446 (Ind. Ct. App. 1996). But the fact that
a person becomes the borrowed servant of another does not necessarily sever the
master-servant relationship between the original parties, for “a person may be the servant
of two masters at one time as to one act, ‘if the service to one does not involve
abandonment of the service to the other.’” Yeary v. United States, 921 F.Supp 549, 558
(S.D. Ind. 1996) (citing N.Y.C. Cent. R.R. Co., 221 N.E.2d at 446)).
This argument fails for the same reasons set forth above – DLS is unable to set
forth any facts to demonstrate that Morris acted solely under the control and employ of
TDS. There is no evidence to suggest that Morris had abandoned his work for DLS on
September 21, 2011.

Further, the fact that TDS may have had an employment

relationship with Morris is immaterial to whether Morris was also acting as an employee
of DLS. Consequently, there remains an issue of fact as to whether Morris acted as a
DLS employee the night of the accident.
B. PLACARD LIABILITY
DLS’s final argument is that, since the TDS-leased Freightliner bore TDS’s placard
at the time of the accident, it is solely liable for the negligence of the truck under placard
liability.

Once again, DLS attempts to use TDS’s potential liability to escape

accountability. It cannot do so.

12

Placard liability provides that motor carriers are vicariously liable for the negligent
actions of a truck driver if the truck bears the motor carrier’s DOT. Rediehs Exp., Inc. v.
Maple, 491 N.E.2d 1006, 1010-11 (Ind. Ct. App. 1986). The purpose of placard liability
is to provide injured parties a “quickly identifiable and financially accountable source of
compensation.” Nat’l Am. Ins. Co. v. Artisan & Truckers Cas. Co., 796 F.3d 717, 724 (7th
Cir. 2015). But, as the Seventh Circuit recently noted, such liability is not exclusive to the
motor carrier alone. “Just because a plaintiff can quickly identify and sue the company
whose placard appeared on the vehicle that struck him does not mean that the same
plaintiff cannot sue–and recover from–others who may be at fault.” Id. at 724-25.
Indiana also follows this line of reasoning. In Johnson v. Motors Dispatch, Inc., the
Indiana Court of Appeals reversed a trial court’s granting of summary judgment to a lessor
that argued placard liability provides for liability against a lessee at the exclusion of other
parties. 360 N.E.2d 224, 229-30 (Ind. Ct. App. 1977). The court held that a lessor, like
DLS, “who is otherwise liable for said negligence is not released by the imposition of
responsibility upon the lessee as well.” Id. at 228. The Johnson court held summary
judgment improper as to the lessor since the driver could have been the employee of both
the lessor and lessee. Id. at 228-29.
The same reasoning holds true in this case. As stated more fully above, DLS fails
to demonstrate that TDS’s liability in this matter excuses its responsibility as Morris’
employer. A question of fact remains as to Morris’ employment status on the night in
question and therefore summary judgment is inappropriate.

13

IV.

CONCLUSION

For the foregoing reasons, the Court DENIES Defendant DLS’s Motion for
Summary Judgment.
IT IS SO ORDERED THIS 15th day of November, 2016.

_____________________________________
LARRY J. McKINNEY, JUDGE
United States District Court
Southern District of Indiana

Distribution:
Pamela J. Hensler
CLENDENING JOHNSON & BOHRER P.C.
[e-mail]
Belinda R. Johnson-Hurtado
CLENDENING JOHNSON & BOHRER P.C.
[e-mail]
Lonnie D. Johnson
CLENDENING JOHNSON & BOHRER, P.C.
[e-mail]
Samantha A. Huettner
CLENDENING JOHNSON & BOHRER, P.C.
[e-mail]
TaKeena Monette Thompson
COHEN & MALAD, LLP
[e-mail]
Keenan C. Fennimore
CRUSER MITCHELL & GASTON, LLC
[e-mail]
Bruce D. Jones
14

CRUSER MITCHELL NOVITZ SANCHEZ & ZIMET, LLP
[e-mail]
Keith A. Gaston
CRUSER MITCHELL NOVITZ SANCHEZ & ZIMET, LLP
[e-mail]
Sally R. Shadwick
CRUSER MITCHELL NOVITZ SANCHEZ & ZIMET, LLP
[e-mail]
Danford Royce Due
DUE DOYLE FANNING & METZGER
[e-mail]
John R. Nelson
FOSTER PEPPER PLLC
422 W. Riverside Ave.
Suite 1310
Spokane, WA 92201
Orfej P. Najdeski
KOPKA PINKUS DOLIN & EADS, LLC
[e-mail]
James H. Milstone
KOPKA, PINKUS DOLIN PC
[e-mail]
Amanda L. Evans
LAW & MORAN
[e-mail]
E. Michael Moran
LAW & MORAN
[e-mail]
Michael P Walker
LAW & MORAN
[e-mail]
Peter A. Law
LAW & MORAN
[e-mail]
Tim D. Mosby
15

LAW OFFICE OF THE LIBERTY MUTUAL GROUP
[e-mail]
Jenna C. Lower
LAW OFFICES OF THE LIBERTY MUTUAL GROUP
[e-mail]
Richard W. McMinn
LAW OFFICES OF THE LIBERTY MUTUAL GROUP
[e-mail]
Mark A. Metzger
METZGER ROSTA LLP
[e-mail]
Thomas Edward Rosta
METZGER ROSTA LLP
[e-mail]
Eric K. Habig
SCOPELITIS GARVIN LIGHT HANSON & FEARY PC
[e-mail]
Thomas E. Schulte
SCOPELITIS GARVIN LIGHT HANSON & FEARY PC
[e-mail]
Christopher R. Whitten
WHITTEN LAW OFFICE
[e-mail]
James L. Culp
WHITTEN LAW OFFICE
[e-mail]
Jason J. Hoy
WHITTEN LAW OFFICE
[e-mail]
Jennifer E. Davis
BRUCE P. CLARK & ASSOCIATES
[e-mail]

Donald J. Tribbett
TRIBBETT LAW OFFICE
16

[e-mail]
Matthew Ryan Dodson
[e-mail]
Thomas David Collignon
COLLIGNON & DIETRICK PC
[e-mail]
Randall Godfrey Degan
DEGAN LAW P.C.
[e-mail]
John K. McDavid
HOSTETTER & ASSOCIATES
[e-mail]
Joel R. Hamner
MCCUTCHEON & HAMNER, PC
[e-mail]

17