EFILED 10/03/19 16:04:58 CASE NO. 19C2346 Richard R.

Rooker, Clerk

IN THE CIRCUIT COURT FOR DAVIDSON COUNTY, TENNESSEE

AT NASHVILLE

ANGELA DOTSON-HEARD, as Administrax )

and Personal Representative, of the Estate of )
Deangelo Dewayne Knox, individually and )
b/n/f of John Doe, a minor child. )
)
)
Plaintiffs, ) No.: 19C2346
)
vs. )
) 12 PERSON
) JURY DEMAND
NATHAN D. GLASS, SPECIALIZED SECURITY )
CONSULTANTS, INC., BRINKMAN )
HOLDING, LLC, Individually and )
BRINKMAN HOLDING, LLC )
4 POINTS HOSPITALITY, LLC, INDIVIDUALLY, )
4 POINTS HOSPITSLITY, LLC, TERRY K. RALEY )
and CEES BRINKMAN, )
)
Defendants. )

AMENDED COMPLAINT

COMES the plaintiff, Angela Dotson-Heard, as administratrix and personal

representative of the estate of Deangelo Dewayne Knox, pursuant to Tenn. Code Ann.

§ 20-5-107 for the use and benefit of the estate of Deangelo Dewayne Knox, deceased and

the minor child, John Doe, and with respect will state and show unto the Court as follows:

1. The plaintiff, Angela Dotson- Heard was appointed as the personal

representative and administratrix of the estate of Deangelo Dewayne Knox on the 23rd day

of May, 2019. See attached as "Exhibit 1" a copy of the letters Testamentary and a copy of

the petition filed in the Probate Court of Davidson County, Tennessee, Docket #19P889,

attached as "Exhibit 2".

 EFILED 10/03/19 16:04:58 CASE NO. 19C2346 Richard R. Rooker, Clerk

2. The plaintiff, Angela Dotson Heard, is an adult citizen and resident of 30865

Hunters Dr., Farmington Hill, Oakland County, Michigan, and the mother of the deceased,

Deangelo Dewayne Knox.

3. The decedent, Deangelo Dewayne Knox, was an adult citizen and resident of

Farmington Hill, Oakland County, Michigan.

4. The minor child, John Doe, is a citizen and resident of Nashville, Davidson

County, Tennessee.

5. The defendant, Nathan D. Glass, upon information and belief is believed to be

a citizen and resident of the State of Tennessee, residing at 3033 Greer Road, Goodlettsville,

Tennessee 37092.

6. The defendant, Specialized Security Consultants, Inc., is a Tennessee

corporation with a principal office address at 11998 Lebanon Road, Mt. Juliet, Tennessee

37122. Defendant, Specialized Security Consultants, may be served through its registered

agent for service or process, Wm. R. Jones, 311 Belinda Parkway, Mt. Juliet, Tennessee

37122.

7. The defendant, Cees Brinkman, is a citizen and resident of Nashville,

Tennessee and may be served with process at 1307 Woodland Street, Nashville, Tennessee

37206.

8. The defendant, Terry Raley, is a citizen and resident of Nashville, Tennessee

and may be served with process at 816 Meridian St., Tennessee 37207.

9. The defendant, Brinkman Holding, LLC is a Tennessee limited liability

company, having its principal place of business in Nashville, Tennessee. Defendant

Brinkman Holdings, LLC may be served with process upon its registered agent Cees
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Brinkman at 1307 Woodland Street, Nashville, Tennessee 37206. Upon information and

belief, Defendant Brinkman is the sole member and agent of Defendant Brinkman Holding,

LLC.

10. The defendant, Terry Raley is a citizen and resident of Nashville, Tennessee

and my be served at 816 Meridian St, Nashville, TN 37207.

11. The defendant, 4 Points Hospitality, LLC is a Tennessee limited liability

company, having its principal place of business at 731 McFerrin Ave. Defendant, 4 Points

Hospitality, LLC may be served with process upon its registered agent, Cees Brinkman at

731 McFerrin Ave. Nashville, TN 37206.

12. This is an action for the wrongful death of Deangelo Dwayne Knox, which

occurred on October 2, 2018, in Nashville, Davidson County, Tennessee which is within the

jurisdiction of this Court.

13. On October 2, 2018, the decedent, Deangelo Dwayne Knox, was in the

eastbound lane on W. Eastland Ave behind two vehicles.

14. On said date, a vehicle with three unknown assailants was in the northbound

lane on McFerrin Avenue in Nashville, Davidson County, Tennessee.

15. The unknown assailants executed a left turn into the westbound lane on W.

Eastland Avenue.

16. As the unknown assailant vehicle drew parallel to the decedent, Deangelo

Dwayne Knox's vehicle, the unknown assailants opened fire on the decedent, Deangelo

Dwayne Knox.

17. The decedent, Deangelo Dwayne Knox moved his vehicle in an easterly

direction on W. Eastland Avenue and collided into a parked vehicle.

 EFILED 10/03/19 16:04:58 CASE NO. 19C2346 Richard R. Rooker, Clerk

18. The decedent, Deangelo Dwayne Knox, exited his vehicle with the unknown

assailants discharging their firearms at him.

19. The decedent, Deangelo Dwayne Knox, proceeded to defend himself and

discharged his firearm towards the assailants.

20. The decedent, Deangelo Dwayne Knox, tried to extricate himself from this

dangerous and life-threatening situation by running in an eastwardly direction on W.

Eastland Avenue and in a northerly direction on McFerrin Avenue past the Pharmacy

Burger Parlor & Beer Garden.

CLAIMS AGAINST NATHAN GLASS

21. At or about the same time, Nathan D. Glass was working as an armed security

guard at the Pharmacy Burger Parlor & Beer Garden as an employee of, Specialized

Security Consultants, Inc. and employed to use deadly force against the general public

22. At all times, Defendant, Nathan D. Glass to all member so of the public

including the decedent, Deangelo Dewayne Knox, to use deadly force reasonable and

prudently.

23. As the decedent, Deangelo Dwayne Knox, attempted to escape this life-

threatening situation, defendant, Nathan D. Glass, as an armed security guard, recklessly

and negligently opened the door to the Pharmacy Burger Parlor & Beer Garden restaurant

and without provocation or threat discharged his weapon killing the decedent, Deangelo

Dwayne Knox as the decedent was running for his life northerly on McFerrin Ave.

24. At no time, did the decedent, Deangelo Dwayne Knox, pose a threat to the

armed security guard, Nathan D. Glass, the general public or any patron doing business at

the Pharmacy Burger Parlor & Beer Garden restaurant.

 EFILED 10/03/19 16:04:58 CASE NO. 19C2346 Richard R. Rooker, Clerk

25. Upon information and belief plaintiffs aver that the defendant, Nathan D.

Glass, was negligent and reckless in his killing of the decedent in his capacity as an armed

security guard while in the employ of Specialized Security Consultants, Inc. and the

Pharmacy Burger Parlor & Beer Garden.

CLAIMS AGAINST SPECIALIZED SECURITY CONSULTANTS

26. Plaintiffs upon information and belief aver that at all times Nathan D. Glass

was an employee of Specialized Security Consultants and that Nathan D. Glass was acting

within the course and scope of his employment at Specialized Security Consultants, Inc.

when he recklessly and negligently killed Deangelo Dewayne Knox.

27. Defendant, Nathan D. Glass’ actions as heretofore described were extremely

reckless and performed with utter disregard of Decedant’s safety and the public safety.

28. The plaintiffs will show that the above act of negligence and recklessness on

the part of the defendant, Nathan D. Glass, is chargeable and imputable to the defendant,

Specialized Security Consultants, Inc., was the direct and proximate cause of the death,

losses and damages sustained by the plaintiffs.

29. Plaintiffs upon information and belief aver that Specialized Security

Consultants failed to properly train, supervise and vet defendant, Nathan D. Glass in the use

of deadly force before Nathan D. Glass negligently and recklessly killed, the decedent,

Deangelo Dewayne Knox.

30. Defendants breached their duty to the decedent, Deangelo Dewayne Knox by

deploying the defendant, Nathan D. Glass, who was not properly trained in the use of

deadly force as an armed security guard.

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CLAIMS AGAINST BRINKMAN HOLDING

31. The above acts of negligence and recklessness on the part of the defendant,

Nathan D. Glass, is dischargeable and imputable to Brinkman Holding, LLC.

32. Plaintiffs upon information and belief aver that Nathan D. Glass and

Specialized Security Consultants were acting within the course and scope of their

employment as armed security to protect the property belonging for Brinkman Holding,

LLC when Nathan D. Glass negligently and recklessly killed Deangelo Dewayne Knox.

33. Defendant, Brinkman Holding, upon information and belief leased its

commercial property to, located at 731 McFerrin Ave, Nashville, Tennessee 37206 to 4

Points Hospitality, LLC.

34. Plaintiffs upon information and belief aver that Brinkman Holding, LLC

breached its duty to the defendant, Deangelo Dewayne Knox, when it negligently failed to

ensure that the security company, Specialized Security Consultants, Inc, that was employed

to protect its premises had properly trained armed security guards, such as Nathan D.

Glass, in the use of deadly, that were not a danger to the public on its premises when the

security guard employed to protect its premises negligently and recklessly killed the

decedent, Deangelo Dewayne Knox.

CLAIMS AGAINST 4 POINTS HOSPITALITY, LLC

35. The above acts of negligence and recklessness on the part of the defendant,

Nathan D. Glass, are dischargeable and imputable to 4 Points Hospitality, LLC individualy

and dba The Pharmacy Burger Parlor and Beer Garden.

36. Plaintiffs upon information and belief that 4 Points Hospitality, LLC, dba The

Pharmacy Burger Parlor and Beer Garden negligently employed, Specialized Security
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Consultants to guard it’s property with deadly force against members of the public which

included the decedent, Deangelo Dewayne Knox.

37. Plaintiffs upon information and belief aver that 4 Points Hospitality, LLC

breached it’s duty to the decedent, Deangelo Dewayne Knox, and the general public, when

it negligently failed to ensure that the security company, Specialized Security Consultants,

Inc, that was employed to protect its premises had properly trained armed security guards

that were not a danger to the public on its premises when the security guard employed to

protect its premises negligently and recklessly killed Deangelo Dewayne Knox.

CLAIMS AGAINST CEES BRINKMAN

38. Upon information and belief, defendant, Cees Brinkman, was the agent and

owner of The Pharmacy Burger Parlor and Beer Garden at the time of the killing of the

decedent, Deangelo Dewayne Knox.

39. Plaintiffs upon information and belief aver that Cees Brinkman breached his

duty to the decedent, Deangelo Dewayne Knox, and the general public, when it negligently

failed to ensure that the security company, Specialized Security Consultants, Inc, that was

employed to protect its premises had properly trained armed security guards that were not

a danger to the public on its premises when the security guard employed to protect its

premises negligently and recklessly killed Deangelo Dewayne Knox.

CLAIMS AGAINST TERRY RALEY

40. Upon information and belief, defendant, Terry Raley, was the agent and

owner of The Pharmacy Burger Parlor and Beer Garden at the time of the killing of the

decedent, Deangelo Dewayne Knox.

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41. Plaintiffs upon information and belief aver that Terry Raley breached his

duty to the decedent, Deangelo Dewayne Knox, and the general public, when it negligently

failed to ensure that the security company, Specialized Security Consultants, Inc, that was

employed to protect its premises had properly trained armed security guards that were not

a danger to the public on its premises when the security guard employed to protect its

premises negligently and recklessly killed Deangelo Dewayne Knox.

42. The foregoing acts proximately caused the wrongful death of the decedent,

Deangelo Dwayne Knox. As a result of the death of Deangelo Dwayne Knox, his surviving

heir was deprived of the comfort, protection, society and support of a kind and loving

father.

43. The plaintiffs bring this cause of action for the wrongful death of the

decedent, Deangelo Dwayne Knox, and for his pain and suffering and the necessary

hospital, ambulance and funeral expenses concerning the decedent, Deangelo Dwayne

Knox.

44. Plaintiffs are entitled to recover punitive damages from the defendants.

45. Plaintiffs upon information and belief aver that Nathan D. Glass and

Specialized Security Consultants were acting within the course and scope of their

employment as armed security for 4 Points Hospitality, LLC when Nathan D. Glass

negligently and recklessly killed Deangelo Dewayne Knox.

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PREMISES CONSIDERED; PLAINTIFFS PRAY:

1. That proper process issue and be served upon the defendants, and that they

be required to answer the complaint filed against them within the time prescribed by law.

2. Upon a final hearing in their cause, the plaintiffs be awarded judgment

against the defendants in the amount of ten million dollars, ($10,000,000.00), for

compensatory damages.

3. Upon a final hearing in this cause, the plaintiffs be awarded judgment against

the defendants for five million dollars, ($5,000,000.00) compensatory damages, for the loss

of the society and companionship of the decedent.

4. Upon a final hearing in this cause, the plaintiffs be awarded judgment against

the defendants in an amount a jury of twelve (12) persons would award in punitive

damages in the amount of $5,000,000.00.

5. That a jury of twelve (12) persons hear this cause.

6. That the cost of this cause be adjudged to the defendants.

7. For such other and further general relief to which plaintiffs may be entitled.
EFILED 10/03/19 16:04:58 CASE NO. 19C2346 Richard R. Rooker, Clerk

Respectfully submitted,

s/ Joy S. Kimbrough with permission s/ Gary M.

Kellar
Joy S. Kimbrough, BPR #25009
Attorney at Law
5570 Knob Road
Nashville, TN 37209
phone: (615)512-0933
phone: (615)753-4797
joykimbrough@gmail.com

SPICER RUDSTROM PLLC

s/ Gary M. Kellar
Gary M. Kellar, BPR# 016170
Bank of America Tower
414 Union Street, Suite 1700
Nashville, Tennessee 37219
(615) 259-9080 – Telephone
(615) 259-1522 – Facsimile
gkellar@spicerfirm.com