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Date: 06-09-2015

Case Style: Heather Nonan and Kurt Morris v. Intergrated Security Solutions, LLC d/b/a Signal 88 Security of Tulsa

Case Number: CJ-2014-485

Judge: Jefferson D. Sellers

Court: District Court, Tulsa County, Oklahoma

Plaintiff's Attorney: Jack Freeman

Defendant's Attorney: Bob James and Jed Isbell

Description: Tulsa, OK - Heather Nonan and Kurt Morris sued Intergrated Security Solutions, LLC d/b/a Signal 88 Security of Tulsa on a civil assault and battery theory claiming:

1. Heather Nonan [“Ms. Nonan”] is a citizen of the State of Oklahoma, residing in Tulsa County, Oklahoma.
2. Kurt Morris [“Mr. Morris”] is a citizen of the State of Oklahoma, residing in Tulsa County, Oklahoma
3. Integrated Security Solutions, LLC is an Oklahoma limited liability company doing business as Signal 88 Security of Tulsa [“Security 88”] in Tulsa county, Oklahoma.
4. The residency of John Doe No. 1 and John Doe No. 2 is not currently known to Plaintiffs.
5. The acts and occurrences that give rise to Plaintiffs’ claims occurred in Tulsa County, State of Oklahoma.
II.
Facts Givin2 Rise To This Suit
6. On July 9, 2013, John Doe No. 1 and John Doe No. 2 assaulted, battered, and wrongfully arrested and detained Plaintiffs while Plaintiffs were occupying a premises where they had a right to be and engaging in peaceful, lawful activity, i.e., enjoying with family and friends the swimming pool and pool area of their apartment complex. John Doe No. 1 and John Doe No. 2 unlawfully and wrongfully arrested, battered, handcuffed with excessive force and detained Ms. Nonan & Mr. Morris for over 2 hours, and at one time exposed Ms. Nonan’s breast - all in the presence of Ms. Nonan’s minor children, I.G.H. and E.C.G. and numerous others.
7. At all times pertinent, John Doe No. 1 and John Doe No. 2 acted within the scope and course of their employment for Integrated Security Solutions, LLC, an Oklahoma limited liability company doing business as Signal 88 Security of Tulsa in Tulsa County, Oklahoma.
III.
Bases of Recovery
8. Plaintiffs reassert by reference the allegations of paragraphs 1 - 7.
9. Defendants, and each of them, owed a duty of reasonable care to Plaintiffs, whom they were hired to serve and protect. Defendants breached that duty and thereby caused Plaintiffs to be damaged.
10. Defendants unlawfully and wrongfully arrested, battered, handcuffed with excessive force and detained Ms. Nonan & Mr. Morris for over 2 hours, and at one time exposed Ms. Nonan’s breast - all in the presence of Ms. Nonan’s minor children, I.G.H. and E.C.G. and numerous others.
Iv.
Damages
11. Plaintiffs reassert by reference the allegations of paragraphs 1 -10.
12. As a result of the actions of the Defendants, and each of them, Plaintiffs have suffered bodily injury and physical pain and suffering, as well as emotional distress.
13. Defendants’ actions were intentional and malicious. Defendants acted in recklessly disregard of the rights of others. Accordingly, exemplary damages should be awarded.

Outcome: Default judgment with motion to vacate filed thereafter by Defendants.

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Defendant's Experts:

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