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Case 1:20-bk-12043 Doc 621 Filed 02/24/21 Entered 02/24/2114:52:42 Desc Main <br /> Document Page 8 of 40 <br /> IN THE CIRCUIT COURT OF MINGO COUNTY <br /> WEST VIRGINIA <br /> KENNETH COLE and <br /> BILLIE JEAN COLE, his wife, <br /> Plaintiffs, <br /> Civil Action No. <br /> CAM MINING, LLC, <br /> a limited liability company, <br /> Defendant. <br /> C01\4PLAINT <br /> Comes now the Plaintiffs, Kennet Cole and Billie Jeai-, Cole, his wife, by counsel, <br /> -insel, <br /> Samuel F Hanna and for their Con-iplaint against the Defendant state and allege as follows: <br /> BACKGROUND <br /> At all tinnes relevant herein, Plaintiff Kenneth Cole was a citizen and resident <br /> of Pikeville, Kentucky. <br /> 2. At all times relevant herein, CAM Mining, LLC is a limited liability company <br /> qualified to conduct business in the State Of West Virginia, and which conducted business <br /> in the State of West Virginia, including Mingo Coulity, <br /> 3. This Court has jurisdiction over this action and venue is proper in the Circuit <br /> Court Of Mingo County because 1) the Defendant conducted business in the State of West <br /> Virginia, including Mingo County, at all times relevant herein and 2)the Defendant's local <br /> property where the incident subject of this complaint is located at 591 Thacker Hollow Rd,, <br /> Matawan, West Virginia, at all times relevant herein. <br />