AFTAB PUREVAL
HAMILTON COUNTY CLERK OF COURTS
COMMON PLEAS DIVISION
ELECTRONICALLY FILED
October 9, 2020 02:51 PM
AFTAB PUREVAL
Clerk of Courts
Hamilton County, Ohio
CONFIRMATION 993907
COURT STREET EXECUTIVE A 2003578
SUITES LLC
vs.
HOWARD FROELICHER IV
FILING TYPE: INITIAL FILING (IN COUNTY) WITH JURY
DEMAND
PAGES FILED: 14
EFR200
E-FILED 10/09/2020 02:51 PM / CONFIRMATION 993907 / A 2003578 / COMMON PLEAS DIVISION / IFIJ
William H. Blessing (0006848)
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
HAMILTON COUNTY OHIO
______________________________________________________________________________
COURT STREET EXECUTIVE SUITES Case No. _____________________
LLC, on behalf of itself and other
similarly situated class members
c/o William H. Blessing
119 East Court Street Suite 500
Cincinnati OH 45202
-vs-
HOWARD FROELICHER IV
23 SOUTHVIEW AVENUE
FT THOMAS KY 41075,
WILLIAM BOGGS
3123 MOZART AVENUE #4
CINCINNATI OH 45211
JACOB CASON
1310 YOUNG STREET
BROUSSARD LA 70518
DARVON ANTON GREEN
745 WOODLAWN AVENUE
CINCINNATI OH 45205
WILLIAM KAMHOLTZ
3287 MORRISON #7
CINCINNATI OH 45220
SARA ABBOUD
2334 VICTOR STREET
CINCINNATI OH 45219
ROWAN M. GRISEZ
483 STONE CREEK WAY
CINCINNATI OH 45103
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BRENNON THOMAS
4201 BRIARWOOD DRIVE
INDEPENDENCE KY 45051
DENZEL CORTEZ PARKS
2507 LANGDON FARM ROAD
CINCINNATI OH 45212
ILLYA IBBOTT
2205 READING ROAD
CINCINNATI OH 45206
CHORD HILL
1577 ELIZABETH PLACE
CINCINNATI OH 45237
EVAN ACKNER
12081 CARRINGTON LANE #102
LOVELAND OH 45140
TERRY BECKHAM
36 APPLEWOOD DRIVE
FAIRFIELD OH 45014
BRIAN DICKENS
5535 WINCHESTER MEADOWS DRIVE
CANAL WINCHESTER, OH 43110
JODY CUNNINGHAM
134 GLENRIDGE PLACE #4
CINCINNATI OH 45217
RANDY CONYERS
353 ROCKDALE
CINCINNATI OH 45229
JOHN COMPTON
122 E. FIFTH STREET
COVINGTON KY 41011
ANTWAN CAMPBELL
7817 NARRWON
CINCINNATI OH 45231
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CHASE BUTLER
1309 WALNUT STREET #304
CINCINNATI OH 45202
PARKER BUSCHELMAN
3303 WATSON
CINCINNATI OH 45231
KATHLEEN BERBERICH
2334 KEMPER LANE
CINCINNATI OH 45206
BETHANY BENNET
6700 JENNIFER LYN DRIVE
CINCINNATI OH 45248
ROBERT EDWARDS
2859 PRESIDENTIAL DRIVE
HEBRON KY 41048
ZOLA BOGGS
6094 BELMONT
CINCINNATI OH 45202
TAYLOR EGGERS
3871 VINE STREET
CINCINNATI OH 45202
THEODORE FLAHERTY
3559 MOONEY AVENUE
CINCINNATI OH 45208
KEERSTEN FELTNER
3009 LAYHIGH ROAD
HAMILTON OH 45013
TYLER GAMBILL
403 N. SECTION EXTENSION
SOUTH LEBANON OH 45065
JARED GAUSLIN
6842 HOME CITY AVENUE
CINCINNATI OH 45233
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BRIDGET DENMAN
3606 W. EIGHTH STREET
CINCINNATI OH 45241
COREY FREEMAN
6362 SIMPSON AVENUE
CINCINNATI OH 45229
YVONNE GASTON
4125 BELL STREET
NORWOOD OH 45212
JARROD GEARY
4125 BELL STREET
NORWOOD OH 45212
ZACHARY GRAY
406 E. FIFTH STREET
NEWPORT KY 42071
TEVIN GREEN
708 GLENWOOD AVENUE
CINCINNATI OH 45229
WILLIAM HANSEN
2362 RAVINE STREET
CINCINNATI OH 45219
HANNAH HARDMAN
5462 MONTGOMERY ROAD
NORWOOD OH 45212
ALEXANDER HARTUNG
7652 CAROLE LANE
FLORENCE KY 42042
EUGENE HASKAMP
324 FAIRFIELD AVENUE
BELLEVUE KENTUCKY 41073
DANIEL HAYNES
1053 OAK GROVE COURT #1
INDEPENDENCE KY 41051
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JOSHUA HEDGES
700 RIDDLE ROAD #503
CINCINNATI OH 45220
NATALIE HAMPFLING
889 SANDSTONE RIDGE
COLD SPRING KY 41076
NICOLE HENNET
3053 MARSHALL AVENUE #9
CINCINNATI OH 45220
CODY HOLBERT
3357 CEDAR TREE LANE
ERLANGER KY 41018
JAYSON HOWARD
2659 WENDLE DRIVE #2028
CINCINNATI OH 45238
JACQUIL ROYAL VOULTEZ HUDSON
1533 MADISON ROAD APT 22
CINCINNATI OH 45206
MARQUISE HUGHES
5400 NEWFIELD AVENUE
CINCINNATI OH 45237
KIYAH JETT
1743 GARDEN LANE
CINCINNATI OH 45237
DAULTON KING
4134 ST. WILLIAMS AVENUE
CINCINNATI OH 45205
DAKOTA LANGHALS
10854 RIDDLES RUN ROAD
UNION KY 41091
ANTHONY LE
335 WEST EIGHTEENTH STREET
NEWPORT KY 41071
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JAGGER LOUDEN
14 UTZ
FLORENCE KY 41042
TANNER MCDOLE
2343 PENNINGTON LANE
CINCINNATI OH 45244
MAXWELL MCDONALD
7505 MONTGOMERY ROAD #15
CINCINNATI OH 45236
JESSICA MORGAN
107 DUDLEY PIKE
EDGEWOOD KY 41022
VANESSA MOSER
3817 EASTERN AVENUE #1
CINCINNATI OH 45226
MELISSA MYRICK
993 SEMINOLE TRAIL
MILFORD OH 45150
RODNEY MYRICK
993 SEMINOLD TRAIL
MILFORD OH 45150
LEWIS MYSZKOWSKI
65 DEERHAVEN COURT
FLORENCE KY 41042
MADISON NUSS
2732 EAST TOWER DRIVE #427
CINCINNATI OH 45238
TYLER O’CONNELL
449 GENERAL DRIVE
FT. WRIGHT KY 41011
JESSICA PARTIN
335 WEST TENTH STREET
NEWPORT KY 41071
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DAVID PALLICASTRO
1942 MAPLE AVENUE
NORWOOD OH 45212
CHRIS PHIFFER
1820 SUNSET AVENUE
CINCINNATI OH 45238
BRYCE PHILLIPS
117 E. TWELFTH STREET
CINCINNATI OH 45202
ALISA POWLEY
3275 BASSWOOD LANE
CINCINNATI OH 45239
MILES ROAT
8551 RATHMAN PLACE
CINCINNATI OH 45255
PAULINE PROKHOROVA
1309 WALNUT STREET
CINCINNATI OH 45202
MICHELLE RICE
4425 HAMILTON AVENUE #1
CINCINNATI OH 45223
KEISHAWN ROBINSON
8779 DESOTO
CINCINNATI OH 45231
IAN SCHEFFLER
1901 MILLS AVENUE #2
NORWOOD OH 45212
SEAN SLACK
213 KLOTTER AVENUE
CINCINNATI OH 45219
HUGH SMITH
1335 MAIN STREET
CINCINNATI OH 45202
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AIDEN SMOCK
1550 TEAKWOOD AVENUE
CINCINNATI OH 45224
DEVIN DARRELL SHAFER
2314 IOWA AVENUE APT #408
CINCINNATI OH 45206
THADDEUS STEWART STEELE
9320 MARKER DRIVE #12
CINCINNATI OH 45251
SIERRA THOMAS
1126 CHAMBERLAIN AVENUE
CINCINNATI OH 45215
DRAKE TURLEY
2770 RUNNING TREE DRIVE
FLORENCE KENTUCKY 41042
IMANI BRAZILLE
8232 W. GALBRAITH ROAD
CINCINNATI OH 45231
JOE VENDITTI
24 CONKLIN STREET
CINCINNATI OH 45219
CALEB VOLLING
8377 MACE AVENUE
CINCINNATI OH 45216
MICHAEL WARDEN
2417 PARK AVENUE
NORWOOD OH 45212
JAMISON WALKER
4401 VIRGINIA AVENUE
CINCINNATI OH 45223
AUSTIN WEINHEIMER
5327 MOELLER AVENUE
NORWOOD OH 45212
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BRANDONLYN WILSON
1302 RESERVOIR STREET
CINCINNATI OH 45211
DREW WITT
448 MORRVUE DRIVE
CINCINNATI OH 45238
COREY WOLFE
290 SALMON PASS
COLD SPRING KY 41010
MARY ZEISER
5064 BEND STREET
CINCINNATI OH 45202
ROBERT ZIEZULKA
401 MARSHAL AVENUE #1013
GEORGETOWN OH 45121
ZACHARY LIPO ZOVIC
135 LYON STREET
CINCINNATI OH 45219
Defendants.
CLASS ACTION COMPLAINT WITH JURY DEMAND
______________________________________________________________________________
Plaintiff Court Street Executive Suites LLC (“CSES”), by its attorneys, brings this class
action complaint for money damages and for equitable relief on behalf of itself and
similarly-situated members of the class described below. To those ends CSES alleges as
follows.
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PRELIMINARY STATEMENT
In 1884, an assembly of protesters marched on the Hamilton County Courthouse. They
were angered by systemic corruption in the county’s criminal justice system and specifically
outraged by a jury’s lenient verdict in a high-profile murder trial. The protest turned into
riot. Shots came from the crowd. Exactly who fired could not be determined. Three days of
pitched battles between law enforcement authorities and rioters ensued. In the end, there
was widespread property damage. Our courthouse was burned. And more than 50 persons
lay dead, including James Desmond whose statue now stands on the first floor of the
current courthouse edifice. Each member of the rioting crowd was civilly and criminally
responsible, because each encouraged, aided, or participated in the riot.
In 2020, from May 29 through 31, protests against the perceived unfairness of criminal
justice in the United States took place in Cincinnati. Late on the evening of May 29, the
assembly turned into riot, which continued for three nights: a concerted course of arson,
assaults, damage to public property and business establishments, as well as extensive looting
in downtown and in the Clifton area. Unlike 1884 and despite a police officer’s being shot in
the head, the 2020 riot did not result in loss of life. However, just as in 1884, those who
participated, connived, conspired, tacitly consented to, aided, abetted, ratified, or
encouraged the rioting are just as responsible for the injuries and damages as are the specific
perpetrators.
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THE PARTIES
1. Plaintiff is an Ohio limited liability company and the owner of certain real property
on Court Street in downtown Cincinnati. Plaintiff brings this action on behalf of the class of
proprietors and real property owners whose properties in downtown Cincinnati, Over-the-
Rhine, West End, Clifton Heights, University Heights, and Fairview were broken into,
looted, vandalized, damaged, defaced, or destroyed by the conduct described below.
2. Each of the Defendants is an individual who has reached age of majority. The
Defendants reside in various states, as indicated in the caption of this Complaint, primarily
in Ohio and Kentucky.
FACTS
3. At various times commencing around 10:00 PM on the evening of May 29, 2020 and
continuing through early June 1, 2020, the named Defendants participated, aided and
abetted, ratified, tacitly consented, and promoted a pattern of riotous conduct in the
downtown, Over-the-Rhine, West End, and Clifton Heights, University Heights, and
Fairview areas of Cincinnati.
4. The unlawful conduct included arson, shooting a Cincinnati police officer in the
head, breaking into, looting, and burglarizing business properties, vandalism, defacing and
otherwise damaging public and private property, theft of property, assaults on law
enforcement officers with firearms, rocks, and bottles, as well as efforts to impede law
enforcement officials from performing their duty to protect persons and property.
5. Each of the Defendants connived and acted to encourage, sponsor, ratify, and
promote the violence and destruction of property that was perpetrated.
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CLASS ALLEGATIONS
6. Pursuant to Ohio Civil Rule 23, Plaintiff proposes to represent a class of persons in
its claims against the Defendants, defined as follows:
All property owners, lessors, tenants, and proprietors of businesses or real
estate in downtown Cincinnati, Over-the-Rhine, West End, Clifton Heights,
University Heights, and East Walnut Hills whose properties or businesses
were vandalized, damaged, destroyed, defaced, or otherwise impaired by the
rioting that occurred from late May 29, 2020 through June 1, 2020.
FIRST CAUSE OF ACTION
CONCERT OF ACTION AND CONSPIRACY
7. Plaintiff, on behalf of itself and the class described above, brings this claim against
each of the named defendants based upon their participation, concerted action and
conspiracy in the rioting and incorporate by reference the allegations stated in Paragraphs 1-
5, above.
8. Each defendant engaged in a malicious combination, conspiracy, and concerted
behavior to perpetrate, promote, ratify, and execute the riotous conduct described in
Paragraph 4, above.
9. Plaintiff and the named class members suffered various damages to their respective
properties or businesses as a direct and proximate result of the rioting and Defendants’
unlawful conduct.
10. Each of the Defendants is jointly and severally liable for the damages, including
economic damages and loss of goodwill, proximately caused by the concerted action and
conspiracy described above and is liable for punitive damages, costs, and attorney fees under
the law of Ohio.
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SECOND CAUSE OF ACTION
STATUTORY LIABILITY UNDER RC 2307.60
11. Plaintiff, on behalf of itself and the class described above, brings this claim against
each of the named Defendants as authorized by RC 2307.60. Plaintiff incorporates the
allegations stated in Paragraphs 1-9, above.
12. The named Defendants and others acting in concert with are jointly and severally
liable for all damages, including economic damages and loss of good will, proximately or
directly caused by the acts described in Paragraphs 4-5, above.
13. The named Defendants are liable for punitive damages, costs, and attorney fees per
RC 2307.60.
THIRD CAUSE OF ACTION: RIOT
14. Plaintiff, on behalf of itself and the class described above, brings this claim against
each of the named Defendants for their engaging in a riot, defined by RC 2917.02. Plaintiff
incorporates the allegations stated in Paragraphs 1-12, above.
15. Each of the named Defendants joined together in promoting, encouraging, and
participating in rioting conduct as defined in RC 2917.02, and each Defendant is liable,
jointly and severally, for all damages, including economic damages and loss of good will,
proximately or directly caused by the rioting.
16. The named Defendants are also liable for punitive damages, costs, and attorney fees
per the law of Ohio.
WHEREFORE, Plaintiff demands that money judgment be entered in favor of it and all
members of the class, jointly and severally against each Defendant as follows:
A. Joint and several judgment for money damages for personal property loss, damages
to real estate, and loss of good will against each Defendant;
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B. An award of punitive damages against each Defendant in an amount sufficient to
punish them for their wrongful conduct and to deter each such Defendant from engaging in
that conduct in the future;
C. An award to Plaintiff of its costs of suit, including attorney fees, as provided by the
common law of Ohio and by statute; and such other relief as may be just and proper.
Respectfully submitted,
/s/ William H Blessing
________________________
William H Blessing (0006848)
Trial Attorney for Plaintiff
BLESSING & WALLACE LAW
119 East Court Street, Suite 500
Cincinnati OH 45202
(513) 621-9191
bill@blessing-attorneys.com
JURY DEMAND
Plaintiff hereby demands its right to trial by jury.
/s/ William H Blessing
___________________________
William H Blessing
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