UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA

CASE NO: _______________________________

WATER STREET SEAFOOD, INC.,

GREG ABRAMS SEAFOOD INC.,

BLUE PARROT OCEANFRONT

CAFE INC., TARPON DOCK SEAFOOD

MARKET, G.A. FISH, INC., WJ2 LLC,

SGI RENTALS, INC., STEVE LIMA a/k/a

CAPTAIN SHELLEY SEAFOOD, and

JOHN S. GRANT, each individually

and on behalf of all others similarly situated,

Plaintiffs,

vs.

BP, p.l.c.; BP PRODUCTS NORTH

AMERICA, INC.; BP AMERICA, INC.;

TRANSOCEAN, LTD.; TRANSOCEAN 

OFFSHORE DEEPWATER DRILLING, INC.;

TRANSOCEAN DEEPWATER, INC.;

HALLIBURTON ENERGY SERVICES, INC.; and 

CAMERON INTERNATIONAL CORPORATION

f/k/a COOPER CAMERON CORPORATION,

Defendants.

/

CLASS ACTION COMPLAINT

1. Plaintiffs, WATER STREET SEAFOOD, INC., GREG ABRAMS SEAFOOD 

INC., BLUE PARROT OCEANFRONT CAFE INC., TARPON DOCK SEAFOOD MARKET, 

G.A. FISH, INC., WJ2 LLC, SGI RENTALS, INC., STEVE LIMA a/k/a CAPTAIN SHELLEY 

SEAFOOD and JOHN S. GRANT, (collectively referred to herein as Plaintiffs ), by 

their undersigned attorneys, on behalf of themselves and all others similarly situated, and 

pursuant to Fed.R.Civ.P. 23, hereby file this Class Action Complaint against Defendants, BP, 

p.l.c, BP PRODUCTS NORTH AMERICA, INC., BP AMERICA, INC. (collectively referred to 

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TRANSOCEAN, LTD., TRANSOCEAN OFFSHORE 

DEEPWATER DRILLING, INC., TRANSOCEAN DEEPWATER, INC. (collectively referred 

HALLIBURTON ENERGY

SERVICES, INC. CAMERON INTERNATIONAL CORPORATION f/k/a 

COOPER CAMERON CORPORATION ( CAMERON ), and allege as follows:

NATURE OF ACTION

2. This is a civil action seeking damages and other appropriate relief arising from the 

unlawful and improper conduct of Defendants towards Plaintiffs and all those similarly situated. 

semisubmersible mobile offshore oil drilling platform known as Deepwater Horizon, on or about 

April 20, 2010. Defendants were operating Deepwater Horizon to drill for oil in an area known 

as the Macondo prospect in Mississippi Canyon Block 252 on the outer Continental Shelf of the 

 As a result of the catastrophic fire, explosion and 

failure of the Deepwater Horizon and its safety devices, there is an ever growing oil slick of 

approximately 600 square miles, and at least 1.6 million gallons of crude oil have leaked from 

the oil well it was completing at the time of the explosion. Thousands of barrels of oil continue 

to leak from the well every day. On April 30, 2010, the State of Florida declared a state of 

emergency because of the oil spill. The oil slick has caused and will continue to cause harmful

effects marine and coastal environments, and their contiguous 

environs, which will severely impact activities Plaintiffs and all others similarly situated rely on 

for income, such as, but not limited to, commercial fishing, seafood processing, distribution and 

consumption, and tourism and tourism related activities. 

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PARTIES

Plaintiffs

3. Plaintiff WATER STREET SEAFOOD, INC. is a wholesale seafood business, is

a Florida corporation owned and operated by Steven C. Rash, and has its principal place of 

business located at 391 Market Street, Apalachicola, Florida.

4. Plaintiff GREG ABRAMS SEAFOOD INC. is a wholesale seafood business, is a 

Florida corporation owned and operated by Greg Abrams, and has its principal place of business 

located at 234 East Beach Drive, Panama City, Florida.

5. Plaintiff BLUE PARROT OCEANFRONT CAFE INC. is an oceanfront

restaurant, is a Florida corporation owned and operated by Steven C. Rash, and has its principal 

place of business located at 68 West Gorrie Drive, St. George Island, Florida.

6. Plaintiff TARPON DOCK SEAFOOD MARKET, is a retail seafood market, is 

owned and operated by Greg Abrams Seafood Inc. and Greg Abrams, and has its principal place 

of business located at 234 East Beach Drive, Panama City, Florida.

7. Plaintiff G.A. FISH, INC. is a commercial fishing business, is a Florida

corporation owned and operated by Greg Abrams, and has its principal place of business located 

at 234 East Beach Drive, Panama City, Florida.

8. Plaintiff WJ2 LLC is a commercial fishing business, is a Florida corporation 

owned and operated by Steven C. Rash, and has its principal place of business located at 391 

Market Street, Apalachicola, Florida.

9. Plaintiff SGI RENTALS, INC. is an oceanfront recreational equipment and jet ski 

rental business, is a Florida corporation owned and operated by Steven C. Rash, and has its 

principal place of business located at 68 West Gorrie Drive, St. George Island, Florida.

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10. Plaintiff STEVE LIMA a/k/a CAPTAIN SHELLEY SEAFOOD is a commercial 

fisherman who owns state and federal fishing licenses and permits, who catches fish in and 

around northwest Florida and in the Gulf of Mexico, and whose business and livelihood is based 

on catching fish for commercial sale in and around northwest Florida and in the Gulf of Mexico. 

11. is a Florida commercial oysterman who 

harvests oysters in and around Florida as a result of owning an oyster llicense. 

business and livelihood is based on the commercial sale of the oysters he harvests

home port is Apalachicola, Florida.

12. CLASS MEMBERS are those persons or entities who, along with Plaintiffs, are 

Defendants

13. Defendant BP, p.l.c.. is a foreign corporation subject to the jurisdiction of the 

courts of Florida by virtue of the conduct alleged herein and/or because it does business in the 

State of Florida.

14. Defendant BP PRODUCTS NORTH AMERICA, INC. is a foreign corporation 

subject to the jurisdiction of the courts of Florida by virtue of the conduct alleged herein and/or 

because it does business in the State of Florida.

15. Defendant BP AMERICA, INC. is a foreign corporation subject to the jurisdiction 

of the courts of Florida by virtue of the conduct alleged herein and/or because it does business in 

the State of Florida.

16. Defendant TRANSOCEAN, LTD. is a foreign corporation subject to the

jurisdiction of the courts of Florida by virtue of the conduct alleged herein and/or because it does 

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business in the State of Florida .

17. Defendant TRANSOCEAN OFFSHORE DEEPWATER DRILLING, INC. is a 

foreign corporation subject to the jurisdiction of the courts of Florida by virtue of the conduct 

alleged herein and/or because it does business in the State of Florida.

18. Defendant TRANSOCEAN DEEPWATER, INC. is a foreign corporation subject 

to the jurisdiction of the courts of Florida by virtue of the conduct alleged herein and/or because 

it does business in the State of Florida.

19. Defendant HALLIBURTON ENERGY SERVICES, INC. is a foreign corporation 

subject to the jurisdiction of the courts of Florida by virtue of the conduct alleged herein and/or 

because it does business in the State of Florida.

20. Defendant CAMERON INTERNATIONAL CORPORATION f/k/a COOPER

CAMERON CORPORATION is a foreign corporation subject to the jurisdiction of the courts of 

Florida by virtue of the conduct alleged herein and/or because it does business in the State of 

Florida.

JURISDICTION AND VENUE

21. Jurisdiction of this Court exists by virtue of 28 U.S.C. §1332(d)(2) and the Class 

different state than at least one Defendant, and the aggregated amount in controversy in this 

action exceeds five million dollars ($5,000,000.00), exclusive of interest and costs. Jurisdiction 

also exists pursuant to 23 U.S.C. §1331 because the harm to Plaintiffs as alleged herein arose 

l areas of Florida 

which gives rise to federal jurisdiction (and incorporating the laws of Florida) pursuant to 43 

U.S.C. §§ 1331(f)(1), 1333(a)(1), and 1333(2)(a).

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22. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(a), (b), and/or (c) 

because a si gnificant number of class members reside in this district, a substantial part of the 

events and occurrences giving rise to this action occurred in this district, a substantial portion of 

property affected by the conduct alleged herein is located in this district, and Defendants are 

subject to the jurisdiction of this Court.

23. Any prior notice to Defendants that may have been required is waived by the 

imminent threat to the legal interests of Plaintiffs.

COMMON FACTUAL ALLEGATIONS

24. The BP Defendants hold the U.S. government granted lease allowing them to 

conduct oil exploration and conduct oil exploration and production related operations in the 

Macondo prospect in Mississippi Canyon Block 252. The BP Defendants were controlling, 

managing, leasing, using, and/or operating Deepwater Horizon in order to conduct its oil

exploration and production venture on April 20, 2010, when it caught fire and catastrophically 

failed and sunk, causing the massive oil spill that is the subject of this lawsuit.

25. The Transocean Defendants were the owners, managers and/or operators of the 

Deepwater Horizon when it caught fire and catastrophically failed and sunk on April 20, 2010, 

causing the massive oil spill that is the subject of this lawsuit.

26. At all times pertinent to this lawsuit, the BP and/or Transocean Defendants were 

responsible for the safe operation of Deepwater Horizon such that a massive oil spill should not 

have occurred, or should have been prevented from occurring.

27. At all times pertinent to this lawsuit, Plaintiffs and Class Members relied on the 

safe operation of the Deepwater Horizon site to prevent the massive oil spill that has harmed and 

will continue to harm their livelihoods.

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28. Drilling platforms such as Deepwater Horizon use a device called a blowout 

-powered guillotine-like slice to the 

drill pipe in the event of a problem and seal the well off. All U.S. offshore oil rigs are mandated 

to have BOPs subject to regular inspection. On Thursday April 28, 2010, in an earnings call to 

investors, Defendant Cameron C.E.O. Jack Moore admitted that Cameron manufactured and 

supplied the BOP on Deepwater Horizon. BOPs are designed to operate automatically in the 

event of a problem without operator input, however, upon information and belief, BP and/or 

Transocean personnel also tried to activate the BOP themselves before evacuating the platform 

and it did not activate. Thus, Defendant Cameron BOP failed to operate as intended and was 

defective as designed and/or manufactured. 

29. Upon information and belief, during a 2009 earnings call to investors, Transocean 

admitted knowledge of BOP problems on at least some of its oil drilling platforms.

30. Defendant Halliburton had been engaged by the BP and/or Transocean 

Defendants to conduct cementing operations on the well. Halliburton has stated that it 

that tests on the integrity of its casing were completed. But, placement of a final cement casing 

plug had not yet occurred at the time of explosion. 

in its cementing duties caused and/or substantially contributed to the explosion and resulting oil 

spill.

31. The catastrophic explosion and failure of the Deepwater Horizon and its safety 

and spill prevention systems, and the 

thus rendering them jointly and severally liable to Plaintiffs and Class Members for their 

damages.

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32. Defendants also committed various statutory and regulatory violations pertaining, 

but not limited to, federal and state laws on oil exploration and pollution, workplace safety, 

marine safety and testing of the BOP. These violations resulted in the harm and damages to 

Plaintiffs and Class Members.

33. The massive oil spill resulting from the Deepwater Horizon incident has harmed, 

will harm and will continue to harm Plaintiffs and Class Members not only because of

nature of the spill makes containment and clean-up 

procedures ineffective, thus causing contamination and pollution of the United States Gulf Coast, 

including Florida, marine life, coastal waters and contiguous environs.

34. Defendants knew or should have known of the risks of a massive oil spill as a 

result of their oil exploration activities and the subsequent harm to Plaintiffs and Class Members,

the United States Gulf Coast, including Florida, marine life, coastal waters and contiguous 

environs. 

35. Upon information and belief, Defendants did not use appropriate measures and 

take appropriate actions to prevent the massive oil spill at the Deepwater Horizon site, and thus 

failed to prevent the harm and damage to Plaintiffs, Class Members, the United States Gulf 

Coast, including Florida, marine life, coastal waters and contiguous environs. 

36. Upon information and

resulted in a failure to install available and appropriate safety and spill prevention devices that 

would have prevented th e oil spill or, at the least, minimized the oil spill, had such devices been 

installed. 

37. Although the full extent of the harm caused by the Deepwater Horizon oil spill 

cannot be ascertained at this time, the oil spill has damaged and will continue to damage the 

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livelihoods and income of Plaintiffs and Class Members. 

CLASS ACTION ALLEGATIONS

38. Plaintiff brings this action on behalf of themselves and all others similarly situated 

pursuant to Fed. R. Civ. P. 23. This action satisfies the numerosity, commonality, typicality, 

adequacy, predominance and superiority requirements of the Rule 23.

39. The proposed class is initially defined as:

All persons or entities who, within the applicable statute of limitations 

preceding the filing of this action and up to the date of class

certification, earn income in, or make their livelihood from Florida

Coastal Zone (as defined by 43 U.S.C. § 1331(e)), and who, as a 

result of the oil spill emanating from the site of the Deepwater Horizon 

explosion and fire on April 20, 2010, have thereby suffered a legally 

cognizable loss and/or damages.

And the following sub-class of Florida commercial seafood industry persons or entities, defined 

as:

All Florida persons or entities who, within the applicable statute of 

limitations preceding the filing of this action and up to the date of class 

certification, derive or derived their income from the commercial

fishing industry by way of fishing, harvesting, processing, wholesale 

distributing, or selling to the public, marine life found in F

result of the oil spill emanating from the site of the Deepwater Horizon 

explosion and fire on April 20, 2010, have thereby suffered a legally 

cognizable loss and/or damages.

And the following sub-class of Florida tourism industry persons or entities, defined as:

All Florida persons or entities who, within the applicable statute of 

limitations preceding the filing of this action and up to the date of class 

certification, derive or derived their income from tourism and tourism 

43 U.S.C. § 1331(e)), and who, as a result of the oil spill emanating 

from the site of the Deepwater Horizon explosion and fire on April 20, 

2010, have thereby suffered a legally cognizable loss and/or damages.

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40. Plaintiffs reserve the right to modify or amend the definition of the proposed 

Classes before the Court determines whether certification is appropriate.

41. Excluded from the Classes are Defendants, their respective parents, subsidiaries, 

affiliates, principals, officers and directors, as well as any entity in which they have controlling 

interests.

42. The number of Class Members is expected to be in the thousands, so the joinder 

of all members is impracticable. All injuries sustained by any member of a Class arise out of the 

same conduct of the Defendants which resulted in the harm to Plaintiffs.

43. Common questions of law and fact exist as to the Classes and predominate over 

in the massive oil spill emanating from the Deepwater Horizon site is generally applicable to the 

entire Class. These common factual and legal questions include, but are not limited to:

a.

harm and damage to Plaintiffs and Class Members;

b. Whether, and to what extent, Defendants were responsible for the safe operation 

and spill prevention measures of the Deepwater Horizon oil exploration platform;

c. Whether, and to what extent, Defendants owed a duty to Plaintiffs and Class 

Members to operate the Deepwater Horizon oil exploration platform in such a 

manner so as to prevent an oil spill and/or substantial threat of an oil spill into the 

United States Gulf Coast area, including the coastal areas of Florida;

d. imately caused, or 

contributed to the fire and catastrophic failure of the Deepwater Horizon and/or its 

safety and spill prevention systems, thus resulting in the massive oil spill;

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e. Whether, and to what extent, the massive oil spill has caused environmental or 

other damage;

f. Whether, and to what extent, Defendants are strictly liable for engaging in an 

abnormally dangerous activity;

g. Whether, and to what extent, Defendants are strictly liable to Plaintiffs and Class 

Members;

h. Whether, and to what extent, Defendants negligently maintained and/or operated 

Deepwater Horizon;

i. Whether Defendants negligently failed to take reasonable, appropriate, and/or 

otherwise available measures to prevent, minimize, or contain the oil spill; and

j. Whether, and to what extent, Plaintiffs and Class Members were harmed and 

suffered damages as a result Defendants conduct and, if so, the appropriate 

measures of damages incurred by Class Members.

44. The claims of the Class representative are typical of the claims of the Classes in 

that Plaintiffs, like all Class Members, have suffered injury and/or will continue to suffer injury 

45. Plaintiffs will fully and adequately represent and protect the interests of the 

Classes because of the common injuries and interests of the Class Members and the conduct of 

Defendants as to all Class Members. The interests of Plaintiffs are coextensive with the interests 

of Class Members, and share common rights of recovery arising from the same essential facts 

and circumstances. Plaintiffs have retained counsel competent and experienced in the

prosecution of class action litigation. Plaintiffs have no interest that is contrary to, or in conflict 

with, those of the Classes they seek to represent.

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46. A class action is superior to all other available methods for fair and efficient 

adjudication of this controversy. There is no difficulty to be encountered in the management of 

this action that would preclude its maintenance as a class action.

47. Class certification is also appropriate in this action because:

a. Pursuant to Fed.R.Civ.P. 23(b)(1)(A), the prosecution of separate actions by 

individual Class Members would create a risk of inconsistent and varying

adjudications concerning the subject of this action, which adjudications could 

establish incompatible duties for Defendants under the law alleged herein.

b. And/or, pursuant to Fed.R.Civ.P. 23(b)(3) the questions of law and fact common 

to all Class Members predominate over any questions that might arise as to an 

individual member, such that a Class Action is the superior, fair and efficient 

method of adjudicating this controversy where, as here, individual claims would 

be identical or nearly identical.

COUNT I

NEGLIGENCE

(Against All Defendants)

48. Plaintiffs incorporate by reference the allegations in Paragraphs 1 47 above as if 

fully set forth herein, and further allege as follows:

49. The fire and catastrophic failure of Deepwater Horizon and its safety and spill 

prevention systems, which resulted in the massive oil spill and harm to Plaintiffs and Class 

concurrent negligence.

50. The Deepwater Horizon, its pipes, casings and the well it was drilling, and all of 

the related equipment and materials, including its safety and spill prevention devices, were in the 

care, custody and control of Defendants at the time of the incident giving rise to this action.

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51. Defendants knew or should have known that their wrongful acts and omissions 

would result in harm and damages in the manner set forth herein.

52. Defendants owed a duty to Plaintiffs and Class Members to exercise reasonable 

care in the design, construction, operation, management, use, maintenance, and inspection of 

Deepwater Horizon, its pipes, casings and the well it was drilling, and all of the related 

equipment and materials, including its safety and spill prevention measures and devices.

53. Defendants breached their duty to Plaintiffs and Class Members by failing to 

properly design, construct, operate, manage, use, maintain and/or inspect Deepwater Horizon, its 

pipes, casings and the well it was drilling, and all of the related equipment and materials, 

including its safety and spill prevention measures and devices, such that Deepwater Horizon 

caught fire, exploded, sunk, and continued to leak oil, resulting in a massive oil spill.

54. Defendants further breached their duty to Plaintiffs and Class Members by failing 

to properly hire, train, manage and supervise personnel on Deepwater Horizon , including the 

proper implementation and enforcement of applicable and appropriate regulations and safety 

measures, such that personnel could have prevented the blow out, and/or reacted to warning 

signs of the blow-out or the blow-out itself such that harm to Plaintiffs and Class Members could 

have been prevented or mitigated.

55. Defendants further breached their duty to Plaintiffs and Class Members by failing 

to properly take appropriate actions to prevent, control or contain the oil spill, including the 

failure to use a working BOP and/or the failure to use and operate available and alternative 

devices to prevent the massive oil spill. 

56. Defendants acted negligently and carelessly without due regard for the safety of 

others and potential harm to Plaintiffs and Class Members.

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57. s and omissions, Plaintiffs and 

Class Members have incurred economic and other damages and are entitled to recover monetary 

damages for, but not limited to: loss of income and revenue, loss of their livelihood, the need to 

relocate, property damage and any incidental or consequential damages resulting from

. 

58. Defendants have conducted themselves in a manner which justifies an award of 

punitive damages.

59. Alternatively, Plaintiffs allege the applicability of the doctrine of res ipsa

loquitur.

COUNT II

STRICT LIABILITY FOR ABNORMALLY DANGEROUS ACTIVITY

(Against All Defendants)

60. Plaintiffs incorporate by reference the allegations in Paragraphs 1 47 above as if 

fully set forth herein, and further allege as follows:

61. By their very operation of Deepwater Horizon, Defendants were engaged in an 

abnormally dangerous activity.

62. drilling operation at the Deepwater Horizon site was an abnormally 

dangerous activity because: 

a. it created a high degree of risk of harm Plaintiffs and Class Members;

b. it would be 

great; 

c.

at their peril, rather than at the expense of the innocent Plaintiffs and Class 

Members who suffered harm as a result of the drilling operation;

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d. oil drilling is not a matter of common usage in the relevant areas of Florida;

e. it was inappropriate to the oil exploration area Defendants were operating in;

f. any value of the operation to the relevant Florida communities was outweighed by 

the abnormal risk of harm and actual harm suffered by Plaintiff and Class

Members.

63. At all times relevant to this action, Defendants were in control of Deepwater 

Horizon and its related drilling operations, as well as its personnel.

64.

physical harm to the waters of United States Gulf Coast, coastal and shore areas and contiguous 

environs, including those of the State of Florida; a harm that is characteristic of the risk posed by 

emanating from the Deepwater Horizon site. 

65. The massive oil spil

causing physical harm to the environments in which, or to property by which, Plaintiffs and 

Class Members make their livelihoods, has caused harm and damage to Plaintiffs and Class 

Members within t

66.

purposes and created a risk to Plaintiffs and Class Members that was not a usual risk expected by 

Plaintiffs and Class Members or a usual incident to their lives or businesses.

67. Plaintiffs and Class Members are entitled to compensatory damages and punitive 

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COUNT III

STRICT LIABlLITY FOR PRODUCT DEFECT

(Against Defendant Cameron)

68. Plaintiffs incorporate by reference the allegations in Paragraphs 1 47 above as if 

fully set forth herein, and further allege as follows:

69. At all times relevant hereto, Defendant Cameron was in the business of designing, 

manufacturing, marketing, selling, and/or distributing the BOP device (s) and system(s) used at 

the Deepwater Horizon site. 

70. Defendant Cameron placed the BOP device(s) and system(s) at the Deepwater 

Horizon site into the stream of commerce.

71. The BOP device(s) and system(s) at the Deepwater Horizon site that were

supplied by Defendant Cameron failed to operate as intended, if at all, and thus caused or 

contributed to the oil spill.

72. D s BOP device(s) and system(s) at the Deepwater Horizon site 

were defective because they were defectively designed and/or were defectively manufactured 

such that they did not operate as intended to prevent or minimize the oil spill.

73. As a result of the defect(s), a massive oil spill emanated from the Deepwater 

Horizon site and has caused, and will continue to cause, harm and damages to Plaintiffs and 

Class Members.

74. At the time the BOP device(s) and system(s) used at the Deepwater Horizon site 

left Defendant Cameron s control, they were in a defective condition and thereby unreasonably 

dangerous to Plaintiffs and Class Members.

75. At all relevant times the BOP device(s) and system(s) used at the Deepwater 

Horizon site were used in the manner intended.

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76. Plaintiffs and Class Members were foreseeable bystanders harmed by the 

defect(s) in 

77. Plaintiffs and Class 

Members have suffered harm and damages in an amount to be determined at trial.

78. In addition to any compensatory damages that may be found, Defendant 

have entitled Plaintiffs and Class Members to 

punitive damages.

COUNT IV

VIOLATION OF FLORIDA STATUTE § 376.302

(Against All Defendants)

79. Plaintiffs incorporate by reference the allegations in Paragraphs 1 47 above as if 

fully set forth herein, and further allege as follows:

80. The oil spill emanating from the Deepwater Horizon site, as a result of

Florida Statute § 376.302(1)(a), 

as a discharge of pollutants and/or hazardous substances into or upon the surface waters of the 

state or lands of Florida, as defined by Florida Statutes §§ 376.301(10), 376.301(11) and 

376.301(13). 

81. Defendants have otherwise violated the provisions of Florida Statutes §§ 376.30 

to 376.317.

82. Defendants had a statutory duty to Plaintiffs and Class Members to design, 

construct, operate, manage, use, maintain, and inspect the Deepwater Horizon, its pipes, casings 

and the well it was drilling, and all of the related equipment and materials, including its safety 

and spill prevention measures and devices, such that pollutants and hazardous substances were 

not discharged into and upon the surface waters and coastal areas of Florida, 

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83. Pursuant to Florida Statute § 376.313(3) Defendants are strictly liable to Plaintiffs 

and Class Members as a result of their conduct which caused the prohibited discharge of 

pollutants and/or hazardous substances. 

84. As a direct and breach of their statutory duties to 

Plaintiffs and Class Members, the oil spill emanating from the Deepwater Horizon site has 

caused detrimental effects to the United States Gulf Coast, including Florida, marine life, coastal 

waters and contiguous environs, which Plaintiffs and Class Members rely on for their income 

and livelihoods.

85. Plaintiffs and Class Members are entitled to statutory damages as well as

herein.

WHEREFORE, Plaintiffs and the Class Members request:

a. Certification of this matter as a class action;

b. Certification of each class as stated herein;

c. An order appointing Plaintiffs as representatives of the Classes;

d. An order appointing undersigned counsel as counsel for the Classes;

e. An award of such damages as are authorized by law, including compensatory,

statutory and punitive damages;

f. s and Class 

Members; 

g. Trial by jury of all matters so triable; and

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h. Such other and further relief as the Court may deem just and proper.

DATED: May 3, 2010.

RESPECTFULLY SUBMITTED BY:

By: s/Jeremy W. Alters, Esquire 

JEREMY W. ALTERS

Florida Bar #111790

jeremy@abbrclaw.com

DAVID C. RASH, ESQUIRE

Florida Bar #0977764

david@abbrclaw.com

Alters, Boldt, Brown, Rash & Culmo, P.A.

4141 Northeast 2nd Avenue, Suite 201

Miami, Florida 33137

Telephone: (305) 571-8550

Facsimile: (305) 571-8558

Attorneys for the Plaintiffs

-andBy: s/Stephen M. Slepin, Esquire 

STEPHEN M. SLEPIN

Florida Bar # 100290

slepin@maddoxhorne.com

Maddox Horne Law Firm

502 North Adams Street

Tallahassee, Florida 32301

Telephone: (850) 222-6020

Facsimile: (850) 222-1249

Attorneys for the Plaintiffs

 

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