10. The section of Pipeline that ruptured was 30 inches in diameter and was buried approximately six feet underground prior to the incident forming the basis of this suit.  11. Upon information and belief, the Pipeline was constructed in 1966 and its interior and exterior walls had corroded to such an extent that a rupture was certain to occur under normal operating pressures if the Pipeline was not repaired and/or replaced.  12. When the Pipeline ruptured, a 75-foot-long section of 30 inch diameter pipe was ejected from underground and natural gas was literally pumped into the air and into the environment surrounding the location of the rupture. The exact amount of natural gas that escaped from the Pipeline into the atmosphere is currently unknown.  13. Natural gas that escaped and that was being pumped through the Pipeline ignited, causing an explosion and fire that burned nearby timberlands and forest, as well as Plaintiff, Janie Thigpen’s home.  15. Florida Gas failed to adequately inform the various federal, state, and local agencies that responded to the incident of the magnitude of the potential danger posed by the Pipeline before the explosion and fire were brought under control, which necessitated a second evacuation from the original “safety zone.”  16. The heat from the explosion and fire was so intense at the site of the rupture that clay and sand under the surface of the ground was baked and turned into a substance that resembled porcelain glass.   17. The intense heat at the site of the explosion caused Plaintiff, Janie Thigpen’s, house to catch fire which resulted in substantial physical damage to her home.  18. Plaintiff, Janie Thigpen, owns the land at the site of the Pipeline rupture and fire, subject to a servitude in favor of Florida Gas for maintenance and operation of the Pipeline.  20. The rupture, explosion, and fire, at issue has caused a substantial decrease in the fair market value of Plaintiff, Janie Thigpen’s, property, to her direct economic detriment.  21. In addition to the property damage and economic loss referenced hereinabove, as a result of the Pipeline rupture, explosion and fire, Plaintiff, Janie Thigpen, sustained bodily injuries, as well as shock to her nervous system and psyche, the final sequella of which is currently unknown.   22. At all times relevant hereto, the Pipeline was owned and/or maintained and/or manned and/or possessed and/or managed and/or controlled and/or chartered and/or operated by Florida Gas.  23. The rupture, fire and explosion of the Pipeline and the damage resulting therefrom was caused by the negligence of Defendant, Florida Gas, which renders Florida Gas liable jointly, severally, and in solido to the Plaintiffs and Class Members for all their damages sustained as a result of the incident forming the basis of this suit.  25. Continued use of the Pipeline following the February 13, 2012, rupture constituted an unreasonable risk of harm to the public, as Defendant, Florida Gas, had actual and/or constructive knowledge of the dangerous condition that existed, namely corrosion of the Pipeline, and failed to take any remedial and/or corrective action to remedy the situation, as is evidenced by the fact that the incident complained of herein is the second occurrence of a failure of the Line 200 natural gas transmission pipeline within a sixteen month period, and Plaintiff and the Members of the Class sustained damages as a result of the rupture, explosion, and fire that occurred on June 18, 2013.    26. The injuries and damages suffered by Plaintiffs and Class Members were caused by Defendant’s violations of numerous statutes and regulations, including, but not limited to, the Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006 (49 U.S.C. 601, et seq.); the Gas Integrity Management Rule (49 CFR §192(O)), including the federally mandated requirements to take corrosion resistance measures and properly test natural gas transmission pipelines at regular intervals.  28. The Pipeline’s rupture, explosion, and fire have caused and will continue to cause loss of revenue and equity value to persons and businesses, including but not limited to Plaintiff and the Class Members, who have sustained a loss in their property values as a result of this incident, as continued operation of the Pipeline poses an unreasonable risk of harm to any individual(s) located within a two mile radius of the Pipeline.  29. There are many other potential effects from the Pipeline rupture, fire, and explosion that have not yet become known, and Plaintiffs reserve the right to amend this Class Action Complaint once additional information becomes available.  30. 33. B. Predominance of Common Questions of Fact and Law: There is a well-defined community of interest and the questions of law and fact common to the Class predominate over questions affecting only individual Class Members and include, but are not limited to, the following: i. Whether Florida Gas caused and/or contributed to the rupture, explosion and fire; ii. Whether the actions of Florida Gas were negligent; iii. Whether the rupture, explosion, and fire have caused environmental or other damage; and iv. The amount of damages Plaintiffs and the Class Members should receive in compensation.  35. D. Adequacy of Representation: Plaintiff will fairly and adequately represent and protect the interests of the Members of the Class because Plaintiff’s interests do not conflict with the interests of the Class Members they seek to represent. Plaintiff does not have any claims antagonistic to those of the Class. Plaintiff has retained counsel competent and experienced in complex litigation, class actions, environmental litigation, and mass tort cases.  37. The various claims asserted in this action are also certifiable under Rules 23(b)(1) and/or 23(b)(3) of the Federal Rules of Civil Procedure because: A. The prosecution of separate actions by hundreds of individual Class Members would create a risk of inconsistent or varying adjudication with respect to individual Class Members, thus entitling incompatible standards of conduct for defendants; B. The prosecution of separate actions by individual Class Members would also create the risk of adjudication with respect to them that would, as a practical matter, be dispositive of the interests of the other Class Members who are not parties to such adjudication and would substantially impair or impede their ability to protect their interests; and C. The questions of law or fact common to the members of the class predominate over any questions affecting only individual Members, and a class action is superior to other available methods for the fair and efficient adjudication of this controversy.  38. 40. The rupture, explosion, and fire, and resulting damages were caused by defective equipment, including but not limited to the Pipeline, gauges, testing equipment, and inspection equipment, which were in the care, custody, and control of Defendant, Florida Gas, and over which Defendant had garde. Florida Gas knew or should have known of these defects and Florida Gas is therefore liable for all damages sustained by Plaintiff, Janie Thigpen, and the Class Members, as alleged herein.  41. The injuries and damages to Plaintiffs and the Class Members were also caused and/or  aggravated by the fact that Defendant, Florida Gas, failed to take necessary actions to mitigate the danger associated with their operations.  42. 44. 45. Plaintiff, Janie Thigpen, and the Members of the Class, expressly plead the doctrine of res ipsa loquitur in connection with all claims set forth herein, as the injuries and damages sustained by Plaintiff and the Class Members would not have occurred but for the acts and/or omissions of Defendant, Florida Gas Transmission Company, L.L.C.   46. Plaintiffs and the Class Members are entitled to a judgment holding the Defendants liable to Plaintiffs and the Class Members for damages suffered as a result of Defendants’ negligence and awarding Plaintiffs and the Class Members adequate compensation therefore in an amount determined by the trier of fact.  47. 49. Defendant, Florida Gas, is vicariously liable for the acts and omissions of its employees, representatives and/or licensed dealer and thus, the law of vicarious liability is applied herein as if set forth in extenso.  50. Defendant, Florida Gas, is therefore liable jointly, severally and in solido unto Plaintiff, Janie Thigpen, and the Class Members, for the damages and losses sustained as a result of the incident complained of herein, which are itemized and non-exclusively set out hereafter.  51. 9. The Pipeline ruptured on June 18, 2013, at approximately 5:25 a.m. CST, near the town of Enon, Louisiana.  A. Numerosity of the Class: The proposed class is so numerous that joinder is impractical. The disposition of the claims asserted herein through this class action will be more efficient and will benefit the parties and the Court.  Florida Gas Transmission Company, L.L.C., is the owner and/or operator of the “Line 200” natural gas transmission pipeline (periodically referred to hereinafter as the “Pipeline.”)  Plaintiff, Janie Thigpen, Individually and on behalf of all those similarly situated, repeats, reiterates, and re-alleges each and every allegation set forth hereinabove as if pled in extenso.  Plaintiff, Janie Thigpen, Individually and on behalf of all those similarly situated, repeats, reiterates, and re-alleges each and every allegation set forth hereinabove as if pled in extenso.  Plaintiff, Janie Thigpen, Individually and on behalf of all those similarly situated, repeats, reiterates, and re-alleges each and every allegation set forth hereinabove as if pled in extenso.  Plaintiff, Janie Thigpen, Individually and on behalf of all those similarly situated, repeats, reiterates, and re-alleges each and every allegation set forth hereinabove as if pled in extenso. 