“ZYNAE GREEN, a minor, by and through her parents and next friends, Carlos Green and Rydricka Rosier, 827 Yardley Drive Prince Frederick, MD 20678 and CARLOS GREEN, JR., a minor, by and through his parents and next friends, Carlos Green and Rydricka Rosier, 827 Yardley Drive Prinee Frederick, MD 20678 and MONYA ROSIER, a minor, by and throngh her parents and next friends, Carlos Green and Rydricka Rosier, 827 Yardley Drive Prince Frederick, MD 20678 and CARLOS GREEN, individually and as father and next friend of his minor children ZYNAE GREEN, CARLOS GREEN, JR. and MONYA ROSIER, 827 Yardley Drive Prince Frederick, MD 20678 and RYDRICKA ROSIER, individually and as mother and next friend of her minor children ZYNAE GREEN, CARLOS GREEN, JR. and MONYA ROSIER, 827 Yardley Drive Prince Frederick, MD 20678 Plaintiffs v. MGM NATIONAL HARBOR, LLC 3950 Las Vegas Blvd South Las Vegas, NV 89119 SERVE: CSC-Lawyers Incorporating Service Company 7 St. Paul Street, Suite 820 Baltimore, MD 21202 IN THE CIRCUIT COURT OF PRINCE GEORGE’S COUNTY, MARYLAND Case No.and NATIONAL HARBOR GRAND, LLC 165 Waterfront Street National Harbor, MD 20745 SERVE: The Corporation Trust, Inc. 2405 York Rd. Suite 201 Lutherville Timinium, MD 21093-2264 and ‘THE WHITING-TURNER CONTRACTING COMPANY 300 E. Joppa Rd. Baltimore, MD 21286 SERVE Timothy J. Regan The Whiting-Turner Contracting Company 300 E. Joppa Rd. Baltimore, MD 21286: and ROSENDIN ELECTRIC, INC 880 Mabury Rd. San Jose, CA 95133 SERVE: The Corporation Trust, Inc. 2405 York Rd. Suite 201 Lutherville iminium, MD 21093-2264 Defendants COMPLAINT Minor plaintiff's Zynae Green (hereinafter “Zynae”), Carlos Green, Jr. (hereinafter, “C.J.”), and Monya Rosier (hereinafter, “Monya”), by and through their parents and next friends, Carlos Green and Rydricka Rosier, and Carlos Green and Rydricka Rosier, individually(collectively, “Plaintifis”), by their attorneys Morelli Law Firm, PLLC and Stein Mitchell Cipollone Beato & Missner LLP, respectfully allege as follows: Nature of the Case 1. Plaintiffs hereby bring this Complaint against defendants MGM National Harbor, LLC (hereinafter, “MGM”), National Harbor Grand, LLC (hereinafter, “National Harbor Grand”), The Whiting-Turning Contracting Company (hereinafter “Whiting-Turner”) and Rosendin Blectrie, Inc. (hereinafter “Rosendin Electric”) (collectively, “Defendants”) for damages arising from severe physical and emotional injuries that Plaintiffs sustained as a result of Defendants’ recklessness. Plaintiffs’ claims arise out of an incident that occurred on the evening of June 26, 2018 at the MGM National Harbor resort and casino located in Oxon Hill, ‘Maryland wherein multiple members of the Green-Rosier family, while visiting the MGM ‘National Harbor resort, were electrocuted by a dangerously electrified metal staircase handrail, which was adjacent to a large fountain and in an area illuminated by bright LED lights. Those Plaintiffs all sustained serious injuries. Minor plaintiff Zynae Green, who is seven years old, sustained the most devastating physical injuries. She went into cardiac arrest as a result of being electrocuted by the handrail, suffered severe and permanent neurologic injuries, was hospitalized in critical condition, and is now in an acute care medical facility. Minor plaintiff Carlos Green, Jr., who is five years-old, and minor plaintiff Monya Rosier, who is sixteen years-old, were both hospitalized for days as a result of their injuries. Rydricka Rosier was not only electrocuted herself, but was also in the zone of danger and witnessed her three children get electrocuted, helped in the efforts to rescue them and saw her youngest daughter Zynae Green go into cardiac arrest. This incident has had a devastating and life-altering impact on the Plaintiffs and their entire family.