IN THE CIRCUIT COURT OF ‘THE FIRST JUDICIAL DISTRICT OF HINDS COUNTY, MISSISSIPPI PAUL STEVEN POGUE, Individually; Paul Steven Pogue as the Administrator of the ESTATE OF DANIEL MARK POGUE; SUSAN JANE JOINER; JOHN THOMAS DEDOUSIS, SR; MADELINE MAIO DEDOUSIS; and JOHN THOMAS DEDOUSIS, JR. ¥ ‘Civil Action Number: 251-09-835CIV KAREN C. IRBY and DEFENDANTS: STUART M. IRBY CROSS-CLAIM COMES NOW, Cross-Claimant, Karen C. Irby, and files this her Cross- Claim against Cross-Defendant, Stuart M. Irby, and for cause of action states the following: 1. Karen C. Irby is an aduit resident citizen of Hinds County, Mississippi. 2. StuartM. Irby is an adult resident citizen of Hinds County, Mississippi, who may be served with this Cross-Claim by serving it upon his attomeys of record in this action. This Court has, jurisdiction over the parties and subject matter of this action and venue is proper with this Court, 3. Onorabout February 11, 2009, Karen C. Irby was driving a car owned by Stuart M. Irby on Old Canton Road in Jackson, Mississippi. At that time, Stuart M. Irby was a passenger in the car. 4. Ther being driven by Karen C. Irby and in which Stuart M. Irby was a passenger, was involved in a collision with a truck being driven by Danie! Mark Pogue. At the time of the collision, Lisa A. Dedousis was a passenger in the truck. 5. Immediately prior to the collision mentioned above, Stuart M. Irby screamed at,threatened, attacked and assaulted Karen C. Irby, cansing and/or contributing to the collision mentioned above. The actions of Stuart. Irby were intentional, reckless, grossly negligent and/or negligent. 6. _Asadirect and proximate cause of the actions of Stuart M. Irby as mentioned above, Karen C. Irby suffered injuries and damages, including, but not limited to, medical bills, pain and suffering and emotional distress. WHEREFORE, PREMISES CONSIDERED, Cross-Claimant, Karen C. Irby demands judgment from and against Cross-Defendant, Stuart M. Irby for any and all damages, fees and cost allowed by law in an amount fo be proved and determined at trial Respectfully submitted, this the __{ ites of May, 2010. KAREN C. IRBY By Cin C bby