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Case 1:20-bk-12043 Doc 621 Document 02/24/21 <br /> Page 8 Entered 02/24/21 14.52:42 Desc Main <br /> 40 <br /> IN THE CIRCUIT COURT OF MINGO COUNTY <br /> 'VEST VIRGINIA <br /> KENNETH COLE and <br /> BILLIE JEAN COLE, his wife, <br /> Plaintiffs, J� <br /> V. Civil Action No. <br /> C7 -rT <br /> CAM MINING, LLC, <br /> a limited liability company, w ; <br /> Defendant. - <br /> -{ N) <br /> COMPLAINT ! ry <br /> Comes now the Plaintiffs, Kenneth Cole and Billie Jean; Cole, his wife, by counsel, <br /> Samuel F Dianna and for their Complaint against the Defendant state and allege as follows: <br /> BACKGROUND <br /> I. At all times relevant herein,Plaintiff Kenneth Cole was a citizen and resident <br /> of Pikeville, Kentucky. <br /> i <br /> 2. At all times relevant herein,CAM Mining,I.LC is a limited liability company 1 <br /> qualified to conduct business in the State of West Virginia, and which conducted business I <br /> i <br /> in the State of West Virginia, including Mingo County. <br /> 3. This Court has jurisdiction over this action and venue is proper in the Circuit t I <br /> Court of Mingo County because 1) the Defendant conducted business in the State of West t <br /> 0 <br /> Virginia, including Mingo County,at all times relevant herein and 2)the Defendant's local <br /> i <br /> property where the incident subject of this complaint is located at 591 Thacker Hollow Rd., � <br /> i <br /> 4 <br /> F <br /> Matawan, West Virginia, at all times relevant herein. <br />