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IN THE UNITED STATES COURT OF FEDERAL CLAIMSMALCOLM & JACKIE ANDRUS, §ELIZABETH
ANN ABBOTT, CARL & §JAMIE ANDERSON, CHAD & MARISSA §ANDERSON, DARYL & TIFFANY
BELL, §MARGARET & BEN BELL, JOEY §BERGERON, LEE & BONNIE BOSSIER, §JANET & BOBBY
BOWMAN, NEIL & §MELISSA BOYETT, CLARENCE §BRAWLEY, CASEY & LINDSAY BROWN, §JOHN &
MELISSA BURGIN, JOE DAVID §& STEPHANIE CAMP, KANDI CHAMPION §& TRAVIS SMITH,
PRESTON & KERRI §CLARK, JANIS & DANIEL CORNETT, §MELISSA & ROBERT COURTNEY,
§LAWRENCE & DOLORES CUSTER, §BYRON & RENEE DAY, JASON §DORCHUCK, ROGER & KAREN
DOYLE, §MARJORIE DUBUISSON, JANIS & JAMES §DUNIGAN, E.L. & MARY ELLENDER, §BARBARA
ENGDAHL, KEN & GINGER §FAULS, RALPH FIELDS, DEMPSEY & § CIVIL ACTION NO.
_______________ MARGARET FRANKLIN, CAROL GATES, §TOM & LISA GRIFFIN, ALICE &
HOWARD §GUILOTT, THOMAS SCOTT & CHARICE §HARRELL, ARCHIE DEAN & RITA KAY §HARRIS,
YIMIN & YUNJIE HUANG HE, §SHIRLEY HOGG, MICHAEL HOLLAND, §CHERYL & KEVIN HUEBEL, L.
KEITH & §DEBRA JORDAN, CHARLES THOMAS §KEEL, LEANNE KENDRICK, JAY & §JENNIFER
KILLGO, LAVOYD & §CLAUDENE KING, BYRON & JULIE LEE, §JOHN LEE, WILBURN & LYNDA LYONS,
§KATHY & JOHN MARSHALL, JEFF & §TIFFANY MATHEWS, EVELYN COKER §MCGEE, KYLE &
LEANNA MCMILLAN, §BRENT & CINDY MENDOZA, JEFFREY §MORRISON, TOMMY PARK, ROBERT
& §KIM PRAK, JEREMY & JESSICA RALEY, §TERI & RICKEY REEL, RACHEL & JOSH §RICH, GARY &
DANA ROBICHAU, §ROB & ROSE RODGERS, FARA ROLLINS §STEVEN MICHAEL SCHNEIDER,
KASHIF §SHAH, ZULFIGAR & SOMIA SHAH,

2LLOYD JAMES SIKES, JIMMY SMITH, §LOLA SMITH, RONALD SMITH, VANN §CHHAI & KAESONE
TAYTHAMA §SOEUING, VANNAK & KIMBERLY §SOEUING, STEPHEN & DEBORAH SONS, §JAMES
SR. & KAREN STEGALL, NORMAN §& WALTRAUD STEHLE, JASON & SANDY §STEVENSON, JOSEPH
THOMPSON, ROB §& JENNIFER TURNER, MARY HELEN §VICKERS, MICHAEL S. WAKEFIELD,
§CAROLYN WARD, ROBERT & DAWNA §WHITMIRE, JUSTIN & ROBIN WILKINS, §JOSEPH &
PATRICIA WINGERSON, §MELISSA & JOE WOODS §Plaintiffs §§V. §§THE UNITED STATES OF
AMERICA §and THE UNITED STATES ARMY §CORPS OF ENGINEERS, §Defendants §

PLAINTIFFS’ ORIGINAL COMPLAINT

TO THE HONORABLE UNITED STATES COURT OF FEDERAL CLAIMS:COMES NOW, Malcom and
Jackie Andrus, Elizabeth Ann Abbott, Carl and JamieAnderson, Chad and Marissa Anderson, Daryl
and Tiffany Bell, Margaret and Ben Bell, JoeyBergeron, Lee and Bonnie Bossier, Janet and Bobby
Bowman, Neil and Melissa Boyett,Clarence Brawley, Casey and Lindsay Brown, John and Melissa
Burgin, Joe David andStephanie Camp, Kandi Champion and Travis Smith, Preston and Kerri
Clark, Janis and DanielCornett, Melissa and Robert Courtney, Lawrence and Dolores Custer,
Byron and Renee Day,Jason Dorchuck, Roger and Karen Doyle, Marjorie Dubuisson, Janis and
Jimmy Dunigan,Barbara Engdahl,, E.L. and Mary Ellender, Ken and Ginger Fauls, Ralph Fields,
Dempsey andMargaret Franklin, Carol Gates, Tom and Lisa Griffin, Alice and Howard Guilott,
Thomas Scottand Charice Harrell, Archie Dean and Rita Kay Harris, Yimin and Yunjie Huang He,
Shirle

3Hogg, Michael Holland, Cheryl and Kevin Huebel, L. Keith and Debra Jordan, Charles
ThomasKeel, Leanne Kendrick, Jay and Jennifer Killgo, Lavoyd and Claudene King, Byron and
JulieLee, John Lee, Wilburn and Lynda Lyons, Kathy and John Marshall, Jeff and Tiffany
Mathews,Evelyn Coker McGee, Kyle and Leanna McMillan, Brent and Cindy Mendoza, Jeffrey
Morrison,Tommy Park, Robert and Kim Prak, Jeremy and Jessica Raley, Teri and Rickey Reel,
Rachel andJosh Rich, Gary and Dana Robichau, Rob & Rose Rodgers, Fara Rollins, Steven
MichaelSchneider, Kashif Shah, Zulfigar & Somie Shah, Lloyd James Sikes, Jimmy Smith, Lola
Smith,Ronald Smith, Vann Chhai and Kaesone Taythama Soeuing, Vannak and Kimberly
Soeuing,Stephen and Deborah Sons, James Sr. and Karen Stegall, Norman and Waltraud Stehle,
Jasonand Sandy Stevenson, Joseph Thompson, Rob and Jennifer Turner, Mary Helen
Vickers,Michael S. Wakefield, Carolyn Ward, Robert and Dawna Whitmire, Justin and Robin
Wilkins,Joseph and Patricia Wingerson, and Melissa and Joe Woods, and file this claim for
theintentional taking of their real and personal property by UNITED STATES OF AMERICA
(“theUnited States”) and the UNITED STATES ARMY CORPS OF ENGINEERS (hereinafter referred
to as “the Corps”) (collectively “Defendants”) entitling them to just compensation under the
Fifth Amendment of the United States Constitution, and in support thereof, show as follows:

I. NATURE OF THE CASE

1. This is a civil action arising under the Fifth Amendment of United States Constitution,seeking
just compensation from Defendants for Defendants’ intentional taking of Plaintiffs’ realand
personal property. The taking of Plaintiffs’ property was a direct and proximate cause of
Defendants’ intentional releases of water from Town Bluff Dam/Dam B on the Neches River
andB.A. Steinhagen Lake.

II. PARTIES

2. Plaintiffs are all individuals and individuals with spouses asserting claims, not as a class, but
independently for compensation for property taken by federal-control flood-water
captured,stored and released from Town Bluff Dam/Dam B on the Neches River and B.A.
SteinhagenLake, beginning August 30, 2017. Specifically, Plaintiffs are:3. Plaintiffs, MALCOLM and
JACKIE ANDRUS, are citizens of the United Statescurrently residing in Orange County, Texas. Mr.
and Mrs. Andrus own a single-family homelocated at 1860 Limerick Dr., Vidor, Texas 77662. As a
result of the Corps’ deliberate capture,storage and release of water, Mr. and Mrs. Andrus seek to
recover just compensation from theCorps for its taking of their real and personal property for
public use.4. Plaintiff, ELIZABETH ANN ABBOTT, is a citizen of the United States currentlyresiding
in Orange County, Texas. Ms. Abbott owns a single-family home located at 2570Heather Glen Dr.,
Vidor, Texas 77662. As a result of the Corps’ deliberate capture, storage andrelease of water, Ms.
Abbott seeks to recover just compensation from the Corps for its taking of her real and personal
property for public use.5. Plaintiffs, CARL and JAIME ANDERSON, are citizens of the United States
currentlyresiding in Orange County, Texas. Mr. and Mrs. Anderson own a single-family home
located at1885 Erin Dr., Vidor, Texas 77662. As a result of the Corps’ deliberate capture, storage
andrelease of water, Mr. and Mrs. Anderson seek to recover just compensation from the Corps
for itstaking of their real and personal property for public use.6. Plaintiffs, CHAD and MARISSA
ANDERSON, are citizens of the United Statescurrently residing in Orange County, Texas. Mr. and
Mrs. Anderson own a single-family homelocated at 1745 Limerick Dr., Vidor, Texas 77662. As a
result of the Corps’ deliberate capture,

5storage and release of water, Mr. and Mrs. Anderson seek to recover just compensation from
theCorps for its taking of their real and personal property for public use.7. Plaintiffs, DARYL and
TIFFANY BELL, are citizens of the United States currentlyresiding in Orange County, Texas. Mr. and
Mrs. Bell own a single-family home located at 2540Waterford Way, Vidor, Texas 77662. As a
result of the Corps’ deliberate capture, storage andrelease of water, Mr. and Mrs. Bell seek to
recover just compensation from the Corps for itstaking of their real and personal property for
public use.8. Plaintiffs, MARGARET and BEN BELL, are citizens of the United States
currentlyresiding in Orange County, Texas. Mr. and Mrs. Bell own a single-family home located at
1860Dublin, Vidor, Texas 77662. As a result of the Corps deliberate capture, storage and release
of water, Mr. and Mrs. Bell seek to recover just compensation from the Corps for its taking of
their real and personal property for public use.9. Plaintiff, JOEY BERGERON, is a citizen of the
United States currently residing inOrange County, Texas. Mr. Bergeron owns single-family homes
located at 1845 Erin St., Vidor,Texas 77662 and 1825 Waterford Way, Vidor, Texas 77662. As a
result of the Corps’ deliberatecapture, storage and release of water, Mr. Bergeron seeks to
recover just compensation from theCorps for its taking of his real and personal property for
public use.10. Plaintiffs, LEE and BONNIE BOSSIER, are citizens of the United States
currentlyresiding in Orange County, Texas. Mr. and Mrs. Bossier own a single-family home
located at1795 Erin, Vidor, Texas 77662. As a result of the Corps’ deliberate capture, storage and
releaseof water, Mr. and Mrs. Bossier seek to recover just compensation from the Corps for its
taking of their real and personal property for public use.11. Plaintiffs, JANET and BOBBY R.
BOWMAN, are citizens of the United States currently
6residing in Orange County, Texas. Mr. and Mrs. Bowman own a single-family home located
at1820 Limerick Dr., Vidor, Texas 77662. As a result of the Corps’ deliberate capture, storage
andrelease of water, Mr. and Mrs. Bowman seek to recover just compensation from the Corps for
itstaking of their real and personal property for public use.12. Plaintiffs, NEIL and MELISSA
BOYETT, are citizens of the United States currentlyresiding in Orange County, Texas. Mr. and Mrs.
Boyett own a single-family home located at1960 Galway Dr., Vidor, Texas 77662. As a result of
the Corps’ deliberate capture, storage andrelease of water, Mr. and Mrs. Boyett seek to recover
just compensation from the Corps for itstaking of their real and personal property for public
use.13. Plaintiff, CLARENCE BRAWLEY, is a citizen of the United States currently residing inOrange
County, Texas. Mr. Brawley own a single-family home located at 5 Kells Cir., Vidor,Texas 77662. As
a result of the Corps’ deliberate capture, storage and release of water, Mr.Brawley seeks to
recover just compensation from the Corps for its taking of their real and personal property for
public use.14. Plaintiffs, CASEY and LINDSAY BROWN, are citizens of the United States
currentlyresiding in Orange County, Texas. Mr. and Mrs. Brown own a single-family home located
at2580 Heather Glen Dr., Vidor, Texas 77662. As a result of the Corps’ deliberate capture,
storageand release of water, Mr. and Mrs. Brown seek to recover just compensation from the
Corps for its taking of their real and personal property for public use.15. Plaintiffs, JOHN and
MELISSA BURGIN, are citizens of the United States currentlyresiding in Orange County, Texas. Mr.
and Mrs. Burgin own a single-family home located at1970 Dublin, Vidor, Texas 77662. As a result
of the Corps’ deliberate capture, storage andrelease of water, Mr. and Mrs. Burgin seek to
recover just compensation from the Corps for its

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