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    Hayley Peterson
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    Complaint and demand for jury trial filed on behalf of Kathleen McLaughlin against Subway

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    Complaint and demand for jury trial filed on behalf of Kathleen McLaughlin against Subway

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    515K views21 pages

    Subway Complaint

    Uploaded by

    Hayley Peterson
    Complaint and demand for jury trial filed on behalf of Kathleen McLaughlin against Subway

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    of 21
    STATE OP INDIANA) HAMILTON SUPERIOR COURTNO. 1 ss: COUNTY OF HAMILTON } causeno: zaporsioct- 404) KATHLEEN MCLAUGHLIN; BF. by ) next of fiend KATHLEEN MCLAUGHLIN; ) and QE, by next offend KATHLEEN ) : MCLAUGHLIN, > = 3 ) x Pats, ) ; . 5 > i ¥ ) aq ) DEMAND FOR DOCTOR'S ASSOCIATES, INC. D/BV/A ) JURY TRIAL SUBWAY; FRANCHISE WORLD ) HEADQUARTERS, LLC; SUBWAY ) FRANCHISEE ADVERTISING FUND ) TRUST,LTD., ) ) Defendants ) COMPLAINT AND DEMAND FOR JURY TRIAL ‘Come now, Kathleen McLaughlin Oka Kathleen Fogle (“Katie”), B.F, by next of friend Kathleen McLaughlin, and Q.F., by next of fiend Kathleen McLaughlin, all by counsel, and submit this Complaint and Demand for Jury Trial and in support of the same state a follows: Parties 1. Katies a United States citizen who has esided within Indiana at all times relevant to this action. 2. BAR. isa minor child, age five, and United States citizen who has resided within Indiana a all times relevant to this action, 3. QF. isaminor child, age three, and United States citizen who has resided within Indiana at ll times relevant to this action. 4, BR Ysand QF.'s next of fiend, Kats, is their biological mother, and she has sole legal and physical custody of them, 5. Katies the now divorced former wife of Jared Fogle. 6. Defendant Doctor's Associates, Inc. d/bfa Subway is a domestic corporation incorporated and existing under the laws ofthe State of Florida with its principal place of ‘business inthe State of Connecticut. 7. Defendant Franchise World Headquarters, LLC is. limited lisblity eompany organized and existing under the laws of the State of Connecticut with its principal place of ‘business inthe State of Connectiut 8, Defendant Subway Franchisee Advertising Fund Trust Lid. (‘SFAFT")is an. ‘unincorporated association and a Connecticut domestic statutory trust, created and existing under the laws of the State of Connecticut, namely Conn. Gen. Stat. § 34-501. ts principal place of busines is in Connecticut. SPAFT"s purpose is to receive, manage and distribute funds to advertise and promote Subway for the benefit of all Subway franchisees, which are located in ‘every state in the United States, including Indiana 9, Upon information and belief, the Defendants, collectively ot one or more of them individually, owns and franchises the Subway restaurant chain and are involved in the marketing, and advertising of the Subway brand and Subway franchises. 10, Defendants are collectively hereinafter refered to as “Subway.” Jurisdiction and Venue 1, This Court has personal jurisdiction over the Defendants as Defendants have systematic and continuous activity within Indiana that is related to the allegations pled inthis matter. Defendants operate ther busines in Indiana and have purposefully availed themselves of the prviloge of conducting activities within Indiana 12, In aiton this Court has persona jurisdiction over the Defendants because Defendants have minimum contacts with and within Indiana tha late to de allegation pled in this mate. 13, Subways ots as allgsd below eased personal injury to Paint a al relevant times while Paintifsesided in Taina. 14. Atoll relevant times Subway had contractual relationship with Jared Fogle (led), Subway’s acts and omissions alleged a the basis ofthis lawsuit re inexticably tied to it relationship with Jared, anda al relevant times, Jared was an Indiana resident. 15. Subway operstes approximately seven hundred (700 sores in Indiana, promates and advertises its busines in and throughout Indiana vi ll ational fos of medi, incloding, but not limited, mao, elevsion, newspapers, mapas, internet, and billboards gon under Indiana Code § 32-36-1-9 for distibuting 16, Subway is subjeot to juts ‘within Indiana advertising material in volation of Indiana Code §32-36-1-8, 17, During and as part of his relationship with Subway, Jared conducted promotional ctivitiesintndian, including without imitation, visting schools and Subway franchises throughout diana 18, Defendants’ rongfl ats oceurted in Indiana, including without imitation,

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