Document jBNXGo2yd3jqZ6BmvjeXawV4O

ALUMINUM COMPANY O nA fn,/'ti 5c3" >r~<~'l i; ^f'' rA\ ALCOA, ; ELF'S NESS EC AL 1978 April 04 Mr. Joe C. Gamble Goddard and Gamble, Attorneys Suite 208, Bank of Maryville Building Post Office Drawer P Maryville, Tennessee 37801 ' SEFcR 3EPLY TO ATrETUTIOM OFr WPITSF! P- O. :lCX 9128 RE: CORNELIUS J. HUNT vs ALUMINUM COMPANY OF AMERICA . . . CIVIL ACTION 4268 - CIRCUIT COURT OF BLOUNT. COUNTY - EQUITY DIVISION STATE OF TENNESSEE_________________________________________ Dear Mr, Gamble: A summons and complaint in the above matter was served on Mr. Richard E. Ray for the Aluminum Company of America on 1978 April 03. This employee was injured 1969 June 28 and was disabled from 1969 June 29 through 1977 April 03, aperiod of 405 weeks and one day, for which he was paid Temporary Total Disability Benefits at REDACTED REDACTED He returned to work on 1977 April 09. We expect to pay a Permanent Partial Disability Benefit to Mr. Hunt, and Dr, Kamperman expects to have him evaluated around 1978 May 01. Please take the necessary steps to protect the Company's interest in this matter. Yours very truly. D. WALKER Compensation Agent Tennessee Operations JDW:sjc cc: R. Jacqueline Bernat/Dave Brown - Pittsburgh E. B. Youngblut/j. E. Burns - Pittsburgh C. L. Kamperman, M.D. - Alcoa, Tennessee kT L- Fair/J. D. Walker, Alcoa, Tennessee File Copy ALTNOP 262912 001 ALCOA_00043785 Alcoa Britton0065729 && * % *** *% SUMMONS IN CIVIL ACTION-CIRCUIT COURT, EQUITY DIVISION wwnxns.<hc.. Nvyva*. row. STATE OF TENNESSEE Circuit Court of Blount County-Equity Division AT MARYVILLE CORNELIUS J. HUNT Plaintiff ALUMINUM CO. OF AMERICA M Defendant; Civil Actic No. _ U260 Summons To the above named Defendants): ALUMINUM CO. OF AMERICA K. You are hereby summoned and required to serve upon D. iX. THOMAS plaintiff's attorney, whose address is______ 206 High St., Maryville, Term. an answer to the complaint which is herewith served upon you within thirty (30) days after service of this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the complaint. Witness, JOHN B. MORTON, Clerk and Master of said court, at office the . 30- . in Mflrfih lift A.D., 19 YQ. John B. Morton CLerk and Master H By- Deputy Clerk and Master 4-268 b) (tcbSzolll Zz tHx) * b. Z o wH 52 O O< *s j_ t3o >*U- Z 1 *s 5 V* *8 <Tt E *8 oHz z Xo Received Ibis _ .day oI_ 19 _ . , Deputy Sheriff. (This summons is issued pursuant to Rule 4 of the Tennessee Rules of Civil Procedure.) RETURN ON SERVICE OF SUMMONS I HEREBY CERTIFY THAT I HAVE SERVED THE WITHIN SUMMON5: By delivering on the ? day t>f CJLfy^gjJ__________ - ar ______M, a copy of the summons and a copy of tbr Complaint to the following defen.da.ntfsi Richard. E. Ra.y__ lor AXUTD . Cv- Olfc AiT1hH.C& By_____ TKUiu.^ SHERIFF _____________________________ ' Deputy Sheriff ALTNOP 262913 001 ALCOA_00043786 Alcoa Britton0065730 LED I, '`'I - < ...... ' . CIRCUIT COURT M Mi'.yvillv. '""'W c^,Ufy.ilml flic lvifl.in l' -> lrt"- ,> o^f too,... ; f A <r)?Cl . M 'RTON filed in enf.e of ............. ............ ...................... is ..... cm IN THE CIRCUIT^jBOUBT FOR BLOUNT COUNTY; TENNESSEE, EQUITY DIVISION CORNELIUS J. HUNT NO. _^Czj ALUMINUM COMPANY OF AMERICA COMPLAINT Comes now your complainant, Cornelius J. Hunt, and would respectfully show unto the court: .I . That he is presently anemployee of the defendant, the Aluminum Company of America, having first gone to work for this company on or about January 29, 1951, and where he continued to work until he was injured on the job on June 28, 1969. At the time your complainant was injured the defendant was employing an adequate number of employees to be subject to the provisions of the Workmen's Compensation Act of the State of Tennessee. n Your complainant would show unto the court that when he had his accident, as above alleged, he was struck by an ore bucket which was being . carried hy a crane, injuring his left leg severely, breaking it in four places, and on account oE which he was hospitalized on three different occasions and went^through a long and difficult recovery period. During the time your complainant was off work with his injuries, which covered a period of approximately seven years and ten months, the defendant company paid him the sum of $42. 00 per week as workmen's compensation benefits for his temporary-total disability. - After your complainant had been back at work for some two weeks hi ALTIMOP 262914 001ALCOA_00043787 Alcoa Britton0065731 sustained an injury to his right hand when he caught his hand between an ore bucket and a roller, severely injuring his hand and on account of which he was disabled again for sometime: however, he was able by way of his own determination to continue working. . III Your complainant would further show unto the'court that he received his last check for initial temporary-total disability period with his left leg on or about April 7, 1977, he having received no compensation for his injury to his hand. , ' IV Your complainant would further show that in addition to his long period of total disability he has sutained numerous arid heavy medical and hospital bills, all of which have been paid by the defendant; however, your complainant avers that he continues to have difficulty with his leg,, that his left leg is some one and one-half inches shorter than his right leg on account of his injuries, that he has suffered involvement with his back and hips and is unable at this time to lift, push or pull any weight and is unable to walk; for any substantial distance. V Your complainant,on account of said injuries his long period of disability and his complications relating thereto, is presently permanently^ partially disabled and account of which he is entitled to future workmen1 s compensation benefits for his permanent-partial disability, and all of which has continued sineb he received hie final compensation check on or about April 7, 1977. VI . Your complainant avers that a true controversy has arisen between him and the defendant as to what his benefits should be and that this question should be decided by this court. -2- ALTNOP 262915 001 ALCOA_00043788 Alcoa Britton0065732 vn PREMISES CONSIDERED, COMPLAINANT PRAYS: 1. That process issue and be served upon fhe defendant at its office in the City of Alcoa, Blount County, Tennessee, requiring it to appear and answer this petition, but its oath to its answer is waived, 2. That the defendant be directed to pay any unpaid medical expenses incurred by this complainant, if any, relating to the subject injury, 3. That the court hear the proof in this cause and determine the nature and extent of complainant's permanent-partial disability and direct the defendant to pay your complainant therefor, either in periodic payments or in a lump sum, whichever the court deems to be proper. 4. Complainant prays far general relief. CORNELIUS J. HUNT ....... BY*^-----D. K. Thomas, his attorney P. O, Box 367 Maryville, Tennessee 37801 ALTNOP 262916 001ALCOA_00043789 Alcoa Britton0065733